Greater Cambridge Local Plan: Proposed Submission

In order to overcome the issues highlighted in this representation and the enclosed Note on Housing
Need and Supply matters and progress a sound Local Plan, it will be necessary to undertake the
following additional work and revise the proposed housing requirement accordingly:
● Increase the housing requirement to reflect as a minimum the minimum local housing need of the
standard method for 48,090 homes.
● Prepare housing projections which align with the economic ambitions set out in the recently adopted
Local Growth Plan, which the CPCA suggest will necessitate a requirement of at least 59,409 homes
but potentially substantially more.
● Consider whether it would be sustainable to deliver a greater number of homes to better respond to
the acute need for affordable housing.
In light of the available evidence, this will necessitate a requirement of at least 59,409 homes over the
plan period to support the local and national economy, rather than the proposed insufficient housing
requirement of 48,069 homes which falls short of meeting even the minimum local housing need and
pays no regard to the level of housing necessary to support the local and national economy.

Jesus College object to Policy S/JH. The policy is unsound as it is not positively prepared, not justified,
not effective and inconsistent with national policy.
These representations are supported by the enclosed Note on Housing Need and Supply Matters. This
concludes that the proposed housing requirement of Policy S/JH is unsound because:
i. It is not positively prepared as it does not meet even the minimum local housing need of the
standard method, let alone reflect the economic ambitions of the government as expressed through the
Local Growth Plan or respond sufficiently to the acute need for affordable housing.
ii. It is not justified as it does not provide any justification for a housing requirement below the
minimum local housing need of the standard method, it does not even consider providing for a level of
housing which aligns with local and national economic growth ambitions, and it has not considered
whether a greater number of homes should be provided to better respond to affordable housing needs.
iii. It will not be effective, as it will not meet housing needs, support local and national economic
ambitions or deliver as much affordable housing as could sustainably be achieved.
iv. It is inconsistent with national policy as it does not meet the minimum local housing need of the
standard method contrary to the requirements of paragraph 62 of the NPPF, and it does not support the
planned economic growth contrary to the PPG (2a-040) and paragraph 86d of the NPPF, and it is not
informed by a consideration of a greater housing requirement to better meet affordable housing needs
contrary to the requirements of the PPG (2a-024).
In terms of the policy context, paragraph 69 of the NPPF (2024) notes an Authority may need to plan for
greater housing growth above their identified need to reflect growth ambitions linked to economic
development or infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024) confirms
that planning policies should seek to address potential barriers to investment, such as inadequate
infrastructure, services or housing, or a poor environment. The draft Plan does not do this. This message
is translated into HO2(b) of the NPPF (2026) and it is clear that housing requirements within Local Plans
should be set higher than the figure identified within a housing needs assessment where appropriate. It is
confirmed that such circumstances include where a higher housing requirement is necessary to reflect
growth ambitions linked to economic investment or infrastructure investment. Whilst the GCLP will be
assessed against the NPPF (2024), it is clear the direction being established by central government is
one of growth, with a particular focus on Cambridge and the surrounding region.
This need for growth is evidenced by national, regional and authority level investment in infrastructure
including the new Cambridge South Railway Station providing direct connectivity between Cambridge
Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and
progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context,
the commitment to East West Rail establishes the area as one benefiting from continued investment in
major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by
the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in
order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for
growth must be realised within the emerging Local Plan.Page 5
The proposed housing requirement of just 48,069 homes in the GCLP, which reflects the minimum
identified by the standard method, will clearly act to constrain the economic ambitions of the Local
Growth Plan contrary to paragraph 86d of the NPPF.
The fact that the GCLP is not planning for the level of growth necessary to support the economic
ambitions of the Local Growth Plan, which align with the economic objectives of the government is
underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even
consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the
basis of standard economic forecasts which are inevitably trend-based and so do not account for
economic potential of the area as is necessary to align with local and national economic ambitions. The
EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the
‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could
be achieved with step change in investment.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater
job growth in the region will generate a derived demand for housing, creating an interdependency
between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of
slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and
homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full
growth potential of the Greater Cambridge economy.
With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central
government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth
Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario.
Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is
acknowledged the Standard Method does not take into account the specific growth agenda and focus on
Cambridge as an area of ‘supercharged growth’.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm
Cambridge’s position as an area capable of supporting and delivering high growth. Within this context
Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The
Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby
growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in
Cambridge and would support the Government’s direction of travel. It is therefore important to recognise
that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision
to the proposed policy wording.
We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum
to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required
delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a
decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in
stating the fact that average household sizes are now larger, leading to an increase in people of working
age and more in-commuting which reduces the number of local people required to fill jobs created. We
raise concern this is an unsustainable approach to development strategy and reflects a local housing
market where many young people are unable to move out of their family homes and move closer to or
within Cambridge where jobs are located at key existing and development employment centres such as
CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to
address the affordability of housing within Greater Cambridge by planning for increased growth and
supply to reflect growing demand rather than embed the issue of increasing household size.
In doing so and making provision for increased housing stock in Greater Cambridge in sustainable
locations would ensure the Local Plan promotes more suitable patterns of travel as required by Page 6
paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys
required for employment.

In order to overcome the issues highlighted within these representations and progress a sound Local
Plan, it will be necessary to:

i. Reassess the plan period supply and the deliverable supply to account for the fact that only
specific sites rather than a windfall allowance can be included in years 1-5 as set out in
paragraph 72a of the NPPF.
ii. Remove sites from the plan period supply where the evidence demonstrates that there is no
intention to bring these forward for residential uses.
iii. Reassess the plan period supply and the deliverable supply to reflect realistic delivery rates at
Northstowe, Cambridge East (airport) and Waterbeach New Town.
iv. Complete the Housing Land Supply Evidence templates of the Planning Inspectorate for each of
these sites included in the deliverable supply, and if necessary, adjust the supply accordingly
including for example where there is no evidence that completions will be achieved.
Having undertaken the preceding work as required by national policy and guidance, it is inevitably the
case that the supply of the GCLP falls very substantially short of providing for a sufficient supply, given
that even with the benefit of the doubt there is:
i. A supply of at most 46,687 homes over the plan period in response to the proposed insufficient
housing requirement of 49,068 homes and the economic need for at least 59,409 homes
identified by the CPCA and
ii. A deliverable supply of at most 11,005 homes over the period 2028-33 in response to the
requirement for either 12,472, 13,562, 15,974 or 18,665 homes depending on whether the
housing requirement reflects economic needs and whether the Liverpool or Sedgefield approach
is applied.
As such, in order to be found sound the GCLP will need to identify additional allocations to deliver a
substantial number of additional homes including to:
i. Meet the economic need for at least 59,409 homes as identified by the CPCA – this requires the
identification of additional allocations which will deliver 12,722 homes over the plan period
without any allowance for headroom.
ii. Provide sufficient headroom (20%) to ensure that the full objectively assessed need is met as
required by paragraphs 11 and 23 of the NPPF – this requires the identification of additional
allocations which will deliver 10,996 more homes over the plan period to meet even the
proposed insufficient housing requirement or 24,604 homes to meet the economic need with a
20% headroom.
iii. Provide for a sufficient supply of specific deliverable sites as required by paragraph 72 of the
NPPF – this requires the identification of additional allocations to deliver either 1,467, 2,557,
4,969 or 7,660 more homes from 2028-33 depending on whether the proposed insufficient
housing requirement or a requirement which supports economic growth is found sound and
whether the Liverpool or Sedgefield approach is supported.
The scale of the insufficiency of the supply in the GCLP is truly exceptional by reference to that which
has arisen in other Local Plans. As such, significant additional work will be required prior to the
submission of the GCLP to identify the necessary additional allocations in order for the GCLP to be found
sound.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is
Land at Rectory Farm, Harston (HELAA 2026 Ref: 115184). Harston is considered a suitable location for
further residential development to support an existing rural community. The site is considered to
represent a sustainable location for development which will help to meet the housing needs of Greater
Cambridge in Local Plan period. With the right design, including a suitable layout and design concept,
the proposed development on the site could be accommodated without having a significant impact on the
surrounding landscape setting.

Jesus College object to Policy S/DS: Development Strategy. The policy is unsound as it is not consistent
with national policy.

These representations are supported by the enclosed Note on Housing Need and Supply Matters. This
concludes that the proposed housing requirement of Policy S/DS is unsound because:
i. It relies upon a windfall allowance of non-specific sites in years 1-5 contrary to paragraph 72 of
the NPPF which only allows for specific sites to be included in this period.
ii. It relies upon sites achieving completions within the plan period, when the available evidence
demonstrates that there is no intention to deliver housing on these.
iii. It relies upon three allocations achieving unprecedented and unrealistic delivery rates.
Once the supply is adjusted to take account of these factors, there is a supply of at most 46,687 homes
over the plan period, rather than the supply of 52,032 suggested in the GCLP.

It is clear that on any basis, the supply of either 46,687 homes or 52,032 homes is insufficient to support
local and national economic growth which requires the delivery of at least 59,409 homes according to the
CPCA or to provide sufficient headroom to meet even the proposed insufficient housing requirement. As
such, the GCLP as drafted will not meet the full objectively assessed need for housing contrary to the
requirements of paragraphs 11 and 23 of the NPPF.

Once the supply is assessed in accordance with national policy, the supply is actually lower than even
the proposed insufficient housing requirement.

Additionally, once the supply is assessed in accordance with national policy and even adopting the most
optimistic assumptions, there is not a sufficient supply of specific deliverable sites for five years following
the intended date of adoption contrary to the requirements of paragraph 72a of the NPPF.
As a consequence, the GCLP is unsound because:

i. It is not positively prepared as it does not provide a sufficient supply of housing to meet even the
proposed insufficient housing requirement, let alone reflect the economic ambitions of the government as
expressed through the Local Growth Plan.
ii. It will not be effective, as it will not meet housing needs or support local and national economic
ambitions, and in fact will actively constrain these objectives being achieved through the proposed
application of the Liverpool approach.
iii. It is inconsistent with national policy as it does not identify a sufficient supply to meet the
objectively assessed need for housing contrary to the requirements of paragraphs 11 and 23 of the
NPPF, and it does not identify a sufficient supply of specific deliverable sites for five years following the
intended date of adoption contrary to the requirements of paragraph 72a of the NPPF.
In terms of the Rest of the Rural Area, we note that this serves a very minor role in the chosen strategy
for this local plan. Figure 9 in the Plan highlights this fact with only 15% of the planned distribution of
growth in the rural area. As referred to in the Bidwells note appended to the Note on Housing Need and
Supply Matters, a strategy which relies too heavily on large allocations risks a lack of delivery in the first
10 years of the Plan due to the significant infrastructure required to service the very large allocations.
This problem is highlighted in paragraph 2.76 of the Plan where the text acknowledges that it must
‘ensure a deliverable plan but which is reliant on a significant level of infrastructure’. Senior Councillors at
Cabinet have also expressed their concerns to officers that this strategy is a risky one to adopt.
We consider this approach flawed as it heavily relies on two very large allocations set out under 2(c) i
Cambourne North (2550 dwellings in plan period) and 2(c) ii Grange Farm (2550 dwellings in the plan
period) which relies on significant infrastructure (namely Cambourne Railway Station to be delivered as
part of East West Rail and CSET respectively) coming forward in a timely manner to service these two
large strategic sites. Further ambiguity is compounded at paragraph 2.80 of the Plan to the strategy as
the Cambridge Wastewater Treatment Works still makes an appearance as a potential development site
even though Government funding for the project has been cancelled by Government.

Our view is that the local plan relies too heavily upon the strategic sites, which will not commence
delivery until the latter half of the plan, after 2035. The plan period is 2024-2045. Our view is that smaller
sites in sustainable settlement locations will be needed for housing delivery in the first 10 years of the
plan. If this does not happen the Plan is unlikely to have sufficient sites available to make up the shortfall
in delivery, as required by Government.

In particular, there are very few small and medium size housing sites allocated in the Rest of the Rural
Area. This lack of housing allocations in the rural area fails to support the delivery of homes to meet the
local housing needs of the next generation during the plan period. Instead of being able to live locally,
this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere
– often away from their existing family, community and support network. This leads to an increased need
for travel within Greater Cambridge, often via private cars rather than public transport. It also results in
population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the
new settlements have predominantly young populations and significant pressure on services.
To ensure the continued vitality of settlements across the Greater Cambridge rural area, an appropriate
degree of housing and employment growth is required to ensure economic footfall is placed into such
settlements and their respective highstreets, services and facilities. The NPPF (2024) explicitly requires
Authorities to enable a sufficient amount of land to come forward for residential development to meet the
housing needs of the whole community - taking into account need, size, type and tenure (NPPF
paragraphs 61 – 63). To meet the needs of the whole Authority we contend a variety of land across the
Authority needs to be identified for development. In allocating the majority of proposed housing at new
settlements and new towns ignores the desire many may have within the Authority to live in the existing
settlements and villages located across the rural area. This further serves to reduce market competition
and choice, which is likely to have a detrimental impact on house prices and market availability.

A more balanced approach is required in respect to the Rural Area, including a wider range of housing
sites being allocated – in terms of both site sizes and locations. This is necessary to ensure that the
Local Plan supports sustainable communities and sustainable patterns of growth. The development
strategy should take account of the needs and vitality of existing villages and the wider rural economy,
making planned provision for them specifically.

In many villages, such as Harston, there is a lack of brownfield land available within the ‘defined
development extents’ to facilitate housing delivery in accordance with the approach set out in Draft Policy
S/SH (Settlement hierarchy). Also, small windfall sites provide limited affordable housing to meet local
needs. Hence, there should be specific land allocations for housing development in some of the rural
villages, to promote genuinely sustainable growth and development – supporting the rural economy,
promoting mixed and inclusive communities and ensuring the vitality and viability of local services.   
Furthermore, Paragraph 73 of the NPPF (2024) stresses the importance of the inclusion of medium and
small sized sites in order to meet the housing requirement of an Authority. They are also essential for
SME housebuilders to deliver new homes whilst being built out relatively quickly by virtue of the often minimal infrastructure requirements. The draft Local Plan does not propose to allocate any new housing
sites to address this requirement, the Evidence Base providing rationale for this that:
● It is challenging to identify a large number of small sites to meet the 10% requirement
● It would undermine the Council’s development strategy and necessitates the release of Green Belt
sites conflicting with the aim of protecting the Cambridge Green Belt as the larger and better served
villages are located within the Green Belt.

The Housing Delivery Addendum Update (2026) argues when accounting for windfall development of
4,953 dwellings coming forward on sites no larger than 1ha then 13.5% of homes over the plan period
will be delivered on small sites. Primarily relying upon windfall development to address as much of the
10% requirement as possible, does not help provide small and medium enterprise housebuilders with the
certainty required to invest in delivering sites. Across Greater Cambridge there has also been a general
decline in the delivery of windfall sites over the years. The Greater Cambridge Housing Delivery Study
Addendum Update (2026) in section 2 considers windfall delivery between 2006 and 2024 and consider
a windfall allowance for 425 dwelling per annum would be robust. This section of the report sets out what
it considers the favourable policy which may assist the delivery of windfall sites in the future. However, it
fails to identify why over time there has been a general trend downward on windfall sites, and whether in
reality, particularly in the South Cambridgeshire area there is now a lack of available sites to continue to
deliver windfall at scale across the plan period. For instance, it presents a data set as far back as 2006 –
2007 for windfall completions to find an average delivery rate of 470 dwellings per annum, fails to realise
that Greater Cambridge has not delivered more than 470 dwellings in a year from windfall since 2016 –
2017. Even if the Council uses 425 dwelling per annum for windfall over the previous seven years of data
the average delivery has been 395 dwellings per annum. As such, there needs to be greater certainty
injected into small and medium sized sites by allocating these in the emerging Local Plan, to aid with
confidence of being able to deliver such sites but also recognising that opportunities for brownfield
redevelopment or residential sub-division can only continue to deliver so much housing across Greater
Cambridge.

The focus upon large new settlements, urban redevelopment and Strategic Urban Extensions also fails
to properly consider the need to offer sufficient choice and flexibility to perspective homeowners. Not all
perspective purchasers will be able to, or wish to buy, in these locations. For instance, existing young
residents of village settlements in South Cambridgeshire may wish to buy a home in the settlement to be
close to existing family for childcare which may not be possible should they have to move to other
proposed allocations.
The proposed development strategy’s lack of commitment to delivering growth in sustainable settlements
in the rural area risks exacerbating the affordability crisis in Greater Cambridge, likely pushing younger
people out of their local communities and support networks. Reliance on strategic settlements outside of
the Green Belt (and hence further away from Cambridge) is also likely to increase car dependency.

In order to ensure that the best windfall Sites come forward to meet the target of 4,953 dwellings and are
of sufficient size to able to make a meaningful affordable housing contribution, we advocate for the
removal of the indicative maximum scheme size in Group Villages.

Jesus College object to Policy S/SH. The policy is unsound as it is not effective.
The indicative maximum scheme sizes are not considered to be necessary for the Group villages.
Windfall development that comes forward within these villages should be considered on the basis of the
site and its context. Schemes should be encouraged to make an efficient and effective use of land whilst
delivering housing development that is appropriate and helps in meeting the needs of the local
community. Often small windfall sites (under the thresholds indicated from Group and Infill Villages) will
provide limited or no affordable housing, exacerbating the situation for newly forming households who
cannot meet their housing needs locally.

Pertinent to ensuring the Plan is sound will require:
● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary

Jesus College object to Policy S/GB. The policy is unsound as it is not effective.

The Development Strategy Topic Paper (2026) states GCSP consider the identified need for 73,300 jobs
and 48,069 new homes across the plan period can be delivered without necessitating the allocation or
release of Green Belt land within the authority area. Notwithstanding given the fundamental changes to
National Policy introduced by the NPPF (2024), notably the introduction of grey belt, the Authority have
prepared and published a revised Greater Cambridge Green Belt Assessment – Review following
changes to National Policy and Guidance (2026) (‘the Green Belt Assessment (2026)’ prepared by LUC.
This is welcomed in principle.

Whilst the GCLP will be examined against the NPPF (2024) it should be noted that the relevant material
consideration for the determination of applications in terms of national policy will be the NPPF (2026).
Annex A (Paragraph 2) of the NPPF (2026) states that Development Plan polices which are materially
inconsistent with the national decision-making polices in the NPPF should be given very limited weight
for the purposes of decision-making. To ensure the GCLP is an effective mechanism for decision
making, particularly with regards to the Green Belt it is considered that GCSP should review the NDMPs
relevant to development in the Green Belt and update S/GB in full to reflect such position. Such policies
that are:
● GB6 (Control of development in the Green Belt)
● GB7 (Development which is not inappropriate in the Green Belt)
● GB8 (Golden rules)

It is considered the identified needs outlined above are too conservative and do not reflect the growth
agenda in national, regional and local contexts mandated by the incumbent Labour government. In line
with the Written Ministerial Statement made by Matthew Pennycook (Minister of State for Housing and
Planning) on 23 October 2025 the ambition remains to ‘supercharge growth’ within the Oxford-Cambridge Corridor and realise the full potential of Greater Cambridge. Furthermore, with the advent of
the Greater Cambridge Development Corporation (backed by £400 million of central government
funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor it is
expected an ambitious growth target will be identified; likely to exceed that currently envisioned by
GCSP. Collectively it remains apparent the government have a continued agenda to deliver high levels of
growth within Greater Cambridge and as such it is considered that GCSP will need to plan for a greater
level of growth as the Local Plan progresses.

Paragraph 146 (NPPF, 2024) (now Policy GB3[2]) identifies that one of the exceptional circumstances in
which Green Belt boundaries can be altered is where an authority cannot meet its identified need for
development in full, having examined other reasonable options. It is noted the Response to Development
Representations – Development Strategy Topic Paper (2026) and the Development Strategy Topic
Paper Appendix 5: Revised Greater Cambridge Local Plan Green Belt Review (2026) that the Authority
do not consider exceptional circumstances for a review of Green Belt boundaries to exist other than the
release of additional land at Cambridge Biomedical Campus (Phase 3) and at Babraham Research
Centre.

However, as identified through the enclosed Note on Housing Need and Supply Matters, Greater
Cambridge’s reliance on the Liverpool Method in calculating their Housing Land Supply runs a significant
risk of under delivery in the early years of the Plan. This is compounded by the Development Strategy’s
reliance on large strategic sites which given the extensive infrastructure requirements for such sites may
face delays to delivery. We raise concern that the reliance will lead to the unsustainable development
patterns and will not ensure a consistent, diverse and appropriate level of housing stock across the plan
period.

The NPPF (2024) is clear at paragraph 146 that exceptional circumstances are not just limited to where
an Authority cannot meet its identified needs in terms of quantum. As noted within our comments on the
Development Strategy, we consider that to ensure a consistent supply that meets the needs of the
Authority across the plan period Greater Cambridge need to consider the allocation of a diverse range of
sites well located to existing settlements to ensure both the longevity of existing settlements and that
growth is delivered and experienced across the Authority.

Paragraph 148 (NPPF, 2024) notes that strategic policy-making authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the
Green Belt boundary, towards towns and villages inset within the Green Belt boundary or towards
locations beyond the outer Green Belt boundary. In considering this, we advocate by virtue of many of
the rural settlements, such as Harston, that these are sustainable locations to facilitate further growth. As
such, the Plan should consider the additional allocation of smaller sites on the edge of settlements inset
into the Green Belt to ensure the Development Strategy is sustainable and provides a robust, diverse
supply of housing across the Authority throughout the plan period.

In considering the above, GCSP may require a further Green Belt review and consider the additional
release of land from the Green Belt to accommodate sustainable and continued growth in the Authority
across the emerging plan period. This would ensure the emerging Local Plan is positively prepared,
justified, effective and consistent with national policy.

One such site that would be suitable to consider for Green Belt release is Land at Rectory Farm, Harston
(HELAA 2026 Ref: 115184). Harston is considered a suitable location for further residential development
to support an existing rural community. The site is considered to represent a sustainable location for
development which will help to meet the housing needs of Greater Cambridge in Local Plan period.
Furthermore, the site itself forms a relatively small area of land within a much larger parcel identified in
the Greater Cambridge Green Belt Assessment (2021) (Parcel HX11).

Additional housing allocations will be required within the Local Plan to ensure the monitoring framework remains robust and fit for purpose.

One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is
Land at Rectory Farm, Harston (HELAA 2026 Ref: 115184). Harston is considered a suitable location for
further residential development to support an existing rural community. The site is considered to
represent a sustainable location for development which will help to meet the housing needs of Greater
Cambridge in Local Plan period. Land at Rectory Farm, Harston (HELAA 2026 Ref: 115184) will ensure
a balanced, diverse and varied supply of housing stock to provide resilience to the Authority’s supply
over the forthcoming plan period, especially during the first 10 years of the plan period.

Jesus College object to Policy S/MO. The policy is unsound as it is not effective.

The draft policy sets out an 8-point mechanism with further details in Appendix E for dealing with under
delivery of housing allocations in the plan. The policy requires the two Councils to monitor the
implementation and performance of the Local Plan against the monitoring indicators set out in the
monitoring framework, set out in Appendix E: Monitoring Framework. However, results will be reported
on annually which is not reactive enough to deal with under delivery. This is clearly illustrated by the
current number of speculative planning applications and appeals taking place in the authority area
because the current adopted local plan allocations are not delivering in a timely manner. The policy
states –

‘If, through monitoring, it appears that policies and allocations are not being achieved, the following
mechanisms will be triggered:
  a. Review of housing and employment land supply and allocations;
  b. Action to bring forward sites for development, wherever possible in partnership with landowners and
developers;
  c. Action to bring forward development on previously developed land;
  d. Action to secure the timely provision of infrastructure;
  e. Review of all, or relevant parts of, the Local Plan;
  f. Review Development Management processes; or
  g. Consider undertaking cooperation with other local authorities, including through duty to cooperate.'

The above mechanisms will not lead to housing delivery in a timely manner as proven by current
applications and appeals. Thus, the GCLP should allocate a number of sustainable and deliverable
housing sites in the local plan to serve delivery in the first 10 years of the Plan due to the envisaged lack
of delivery on the very large allocations in the Plan which require significant infrastructure to deliver them.

In order to overcome the issues highlighted within these representations and progress a sound Local
Plan, it will be necessary to:

i. Reassess the plan period supply and the deliverable supply to account for the fact that only
specific sites rather than a windfall allowance can be included in years 1-5 as set out in
paragraph 72a of the NPPF.
ii. Remove sites from the plan period supply where the evidence demonstrates that there is no
intention to bring these forward for residential uses.
iii. Reassess the plan period supply and the deliverable supply to reflect realistic delivery rates at
Northstowe, Cambridge East (airport) and Waterbeach New Town.
iv. Complete the Housing Land Supply Evidence templates of the Planning Inspectorate for each of
these sites included in the deliverable supply, and if necessary, adjust the supply accordingly
including for example where there is no evidence that completions will be achieved.

Having undertaken the preceding work as required by national policy and guidance, it is inevitably the
case that the supply of the GCLP falls very substantially short of providing for a sufficient supply, given
that even with the benefit of the doubt there is:
i. A supply of at most 46,687 homes over the plan period in response to the proposed insufficient
housing requirement of 49,068 homes and the economic need for at least 59,409 homes
identified by the CPCA and
ii. A deliverable supply of at most 11,005 homes over the period 2028-33 in response to the
requirement for either 12,472, 13,562, 15,974 or 18,665 homes depending on whether the
housing requirement reflects economic needs and whether the Liverpool or Sedgefield approach
is applied.

As such, in order to be found sound the GCLP will need to identify additional allocations to deliver a
substantial number of additional homes including to:
i. Meet the economic need for at least 59,409 homes as identified by the CPCA – this requires the
identification of additional allocations which will deliver 12,722 homes over the plan period
without any allowance for headroom.
ii. Provide sufficient headroom (20%) to ensure that the full objectively assessed need is met as
required by paragraphs 11 and 23 of the NPPF – this requires the identification of additional
allocations which will deliver 10,996 more homes over the plan period to meet even the
proposed insufficient housing requirement or 24,604 homes to meet the economic need with a
20% headroom.
iii. Provide for a sufficient supply of specific deliverable sites as required by paragraph 72 of the
NPPF – this requires the identification of additional allocations to deliver either 1,467, 2,557,
4,969 or 7,660 more homes from 2028-33 depending on whether the proposed insufficient
housing requirement or a requirement which supports economic growth is found sound and
whether the Liverpool or Sedgefield approach is supported.

The scale of the insufficiency of the supply in the GCLP is truly exceptional by reference to that which
has arisen in other Local Plans. As such, significant additional work will be required prior to the
submission of the GCLP to identify the necessary additional allocations in order for the GCLP to be found
sound.

One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is
Land at Rectory Farm, Harston (HELAA 2026 Ref: 115184). Harston is considered a suitable location for
further residential development to support an existing rural community. The site is considered to
represent a sustainable location for development which will help to meet the housing needs of Greater
Cambridge in Local Plan period. With the right design, including a suitable layout and design concept,
the proposed development on the site could be accommodated without having a significant impact on the
surrounding landscape setting.

Paragraph 1.6 of the Sustainability Appraisal (2026) (‘SA’) states ‘Developing options for a plan is an
iterative process, involving a number of consultations with stakeholders and the public. The SA process
can help to identify where there may be other ‘reasonable alternatives’ to the options being considered
for the policies to be included in a plan.’ These options are explained and their effects summarised in
Chapter 4 of the full SA report.
Paragraph 2.10 of the SA states ‘The SA findings are not the only factors taken into account when
determining a preferred option to take forward in a plan. Indeed, there will often be an equal number of
positive or negative effects identified for each option, such that it is not possible to ‘rank’ them based on
sustainability performance in order to select a preferred option. Factors such as public opinion,
deliverability and conformity with national policy will also be taken into account by plan makers when
selecting preferred options for their plan.
It is clear is that the proposed Development Strategy underpinning the Regulation 19 Local Plan is not a
sufficiently robust development strategy which positively plans for housing delivery in the first 10 years or
so of the plan period. This is because the strategy relies very heavily on the deliverability of two very
large strategic sites at Cambourne North and Grange Farm, between them accounting for 5,100
dwellings in the plan period, which are very likely to be delayed due to the significant infrastructure
required to deliver the housing numbers. Indeed, in a site-specific sense, Grange Farm represents a late
allocation entry (due to the Cambridge Waste Water Treatment Works de-allocation) jumping the Green
Belt into open countryside. As such, Grange Farm has poor public transport connectivity beyond the A1
and senior councillors have expressed concerns about the potentially very high number of car-generated
trips expected due to the divorced nature of site from the planned Travel Hub south of Babraham village.
The Infrastructure Delivery Plan states a ‘Shuttle / commuter services connecting Grange Farm to nearby
campuses and railway stations will be essential’ to service this site. It is further noted the Housing
Delivery Study Addendum (2026) identifies Phase 2 of CSET is essential for the delivery of Grange Farm
(3.2.66). It notes that the timescales for delivery and phasing of CSET are still being discussed and that
the conclusion of these discussions will dictate when a full site build-out to align with typical assumptions
can be achieved. It is therefore considered the Development Strategy as currently proposed relies
significantly on assumptions on the timely delivery of infrastructure which given the ongoing difficulties
with the delivery of Cambourne to Cambridge (C2C) is high risk.

In order to overcome the issues highlighted in this representation and the enclosed Note on Housing
Need and Supply matters and progress a sound Local Plan, it will be necessary to undertake the
following additional work and revise the proposed housing requirement accordingly:
● Increase the housing requirement to reflect as a minimum the minimum local housing need of the
standard method for 48,090 homes.
● Prepare housing projections which align with the economic ambitions set out in the recently adopted
Local Growth Plan, which the CPCA suggest will necessitate a requirement of at least 59,409 homes
but potentially substantially more.
● Consider whether it would be sustainable to deliver a greater number of homes to better respond to
the acute need for affordable housing.
In light of the available evidence, this will necessitate a requirement of at least 59,409 homes over the
plan period to support the local and national economy, rather than the proposed insufficient housing
requirement of 48,069 homes which falls short of meeting even the minimum local housing need and
pays no regard to the level of housing necessary to support the local and national economy.

Jesus College object to Policy S/JH. The policy is unsound as it is not positively prepared, not justified,
not effective and inconsistent with national policy.

These representations are supported by the enclosed Note on Housing Need and Supply Matters. This
concludes that the proposed housing requirement of Policy S/JH is unsound because:
i. It is not positively prepared as it does not meet even the minimum local housing need of the
standard method, let alone reflect the economic ambitions of the government as expressed through the
Local Growth Plan or respond sufficiently to the acute need for affordable housing.
ii. It is not justified as it does not provide any justification for a housing requirement below the
minimum local housing need of the standard method, it does not even consider providing for a level of
housing which aligns with local and national economic growth ambitions, and it has not considered
whether a greater number of homes should be provided to better respond to affordable housing needs.
iii. It will not be effective, as it will not meet housing needs, support local and national economic
ambitions or deliver as much affordable housing as could sustainably be achieved.
iv. It is inconsistent with national policy as it does not meet the minimum local housing need of the
standard method contrary to the requirements of paragraph 62 of the NPPF, and it does not support the
planned economic growth contrary to the PPG (2a-040) and paragraph 86d of the NPPF, and it is not
informed by a consideration of a greater housing requirement to better meet affordable housing needs
contrary to the requirements of the PPG (2a-024).

In terms of the policy context, paragraph 69 of the NPPF (2024) notes an Authority may need to plan for
greater housing growth above their identified need to reflect growth ambitions linked to economic
development or infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024) confirms
that planning policies should seek to address potential barriers to investment, such as inadequate
infrastructure, services or housing, or a poor environment. The draft Plan does not do this. This message
is translated into HO2(b) of the NPPF (2026) and it is clear that housing requirements within Local Plans
should be set higher than the figure identified within a housing needs assessment where appropriate. It is
confirmed that such circumstances include where a higher housing requirement is necessary to reflect
growth ambitions linked to economic investment or infrastructure investment. Whilst the GCLP will be
assessed against the NPPF (2024), it is clear the direction being established by central government is
one of growth, with a particular focus on Cambridge and the surrounding region.

This need for growth is evidenced by national, regional and authority level investment in infrastructure
including the new Cambridge South Railway Station providing direct connectivity between Cambridge
Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and
progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context,
the commitment to East West Rail establishes the area as one benefiting from continued investment in
major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by
the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for
growth must be realised within the emerging Local Plan.

The proposed housing requirement of just 48,069 homes in the GCLP, which reflects the minimum
identified by the standard method, will clearly act to constrain the economic ambitions of the Local
Growth Plan contrary to paragraph 86d of the NPPF.

The fact that the GCLP is not planning for the level of growth necessary to support the economic
ambitions of the Local Growth Plan, which align with the economic objectives of the government is
underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even
consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the
basis of standard economic forecasts which are inevitably trend-based and so do not account for
economic potential of the area as is necessary to align with local and national economic ambitions. The
EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the
‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could
be achieved with step change in investment.

Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater
job growth in the region will generate a derived demand for housing, creating an interdependency
between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of
slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and
homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full
growth potential of the Greater Cambridge economy.

With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central
government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth
Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario.
Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is
acknowledged the Standard Method does not take into account the specific growth agenda and focus on
Cambridge as an area of ‘supercharged growth’.

It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm
Cambridge’s position as an area capable of supporting and delivering high growth. Within this context
Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The
Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby
growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in
Cambridge and would support the Government’s direction of travel. It is therefore important to recognise
that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision
to the proposed policy wording.

We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum
to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required
delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a
decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in
stating the fact that average household sizes are now larger, leading to an increase in people of working
age and more in-commuting which reduces the number of local people required to fill jobs created. We
raise concern this is an unsustainable approach to development strategy and reflects a local housing
market where many young people are unable to move out of their family homes and move closer to or
within Cambridge where jobs are located at key existing and development employment centres such as
CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to
address the affordability of housing within Greater Cambridge by planning for increased growth and
supply to reflect growing demand rather than embed the issue of increasing household size.

In doing so and making provision for increased housing stock in Greater Cambridge in sustainable
locations would ensure the Local Plan promotes more suitable patterns of travel as required by
paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys
required for employment.

In order to overcome the issues highlighted within these representations and progress a sound Local
Plan, it will be necessary to:
i. Reassess the plan period supply and the deliverable supply to account for the fact that only
specific sites rather than a windfall allowance can be included in years 1-5 as set out in
paragraph 72a of the NPPF.
ii. Remove sites from the plan period supply where the evidence demonstrates that there is no
intention to bring these forward for residential uses.
iii. Reassess the plan period supply and the deliverable supply to reflect realistic delivery rates at
Northstowe, Cambridge East (airport) and Waterbeach New Town.
iv. Complete the Housing Land Supply Evidence templates of the Planning Inspectorate for each of
these sites included in the deliverable supply, and if necessary, adjust the supply accordingly
including for example where there is no evidence that completions will be achieved.
Having undertaken the preceding work as required by national policy and guidance, it is inevitably the
case that the supply of the GCLP falls very substantially short of providing for a sufficient supply, given
that even with the benefit of the doubt there is:
i. A supply of at most 46,687 homes over the plan period in response to the proposed insufficient
housing requirement of 49,068 homes and the economic need for at least 59,409 homes
identified by the CPCA and
ii. A deliverable supply of at most 11,005 homes over the period 2028-33 in response to the
requirement for either 12,472, 13,562, 15,974 or 18,665 homes depending on whether the
housing requirement reflects economic needs and whether the Liverpool or Sedgefield approach
is applied.
As such, in order to be found sound the GCLP will need to identify additional allocations to deliver a
substantial number of additional homes including to:
i. Meet the economic need for at least 59,409 homes as identified by the CPCA – this requires the
identification of additional allocations which will deliver 12,722 homes over the plan period
without any allowance for headroom.
ii. Provide sufficient headroom (20%) to ensure that the full objectively assessed need is met as
required by paragraphs 11 and 23 of the NPPF – this requires the identification of additional allocations which will deliver 10,996 more homes over the plan period to meet even the
proposed insufficient housing requirement or 24,604 homes to meet the economic need with a
20% headroom.
iii. Provide for a sufficient supply of specific deliverable sites as required by paragraph 72 of the
NPPF – this requires the identification of additional allocations to deliver either 1,467, 2,557,
4,969 or 7,660 more homes from 2028-33 depending on whether the proposed insufficient
housing requirement or a requirement which supports economic growth is found sound and
whether the Liverpool or Sedgefield approach is supported.
The scale of the insufficiency of the supply in the GCLP is truly exceptional by reference to that which
has arisen in other Local Plans. As such, significant additional work will be required prior to the
submission of the GCLP to identify the necessary additional allocations in order for the GCLP to be found
sound.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is
Land to the south of Station Road, Harston (HELAA 2026 Ref: 115742). Harston is considered a suitable
location for further residential development to support an existing rural community. The site is considered
to represent a sustainable location for development which will help to meet the housing needs of Greater
Cambridge in Local Plan period. With the right design, including a suitable layout and design concept,
the proposed development on the site could be accommodated without having a significant impact on the
surrounding landscape setting.

Jesus College object to Policy S/DS: Development Strategy. The policy is unsound as it is not consistent
with national policy.

These representations are supported by the enclosed Note on Housing Need and Supply Matters. This
concludes that the proposed housing requirement of Policy S/DS is unsound because:
i. It relies upon a windfall allowance of non-specific sites in years 1-5 contrary to paragraph 72 of
the NPPF which only allows for specific sites to be included in this period.
ii. It relies upon sites achieving completions within the plan period, when the available evidence
demonstrates that there is no intention to deliver housing on these.
iii. It relies upon three allocations achieving unprecedented and unrealistic delivery rates.
Once the supply is adjusted to take account of these factors, there is a supply of at most 46,687 homes
over the plan period, rather than the supply of 52,032 suggested in the GCLP.
It is clear that on any basis, the supply of either 46,687 homes or 52,032 homes is insufficient to support
local and national economic growth which requires the delivery of at least 59,409 homes according to the
CPCA or to provide sufficient headroom to meet even the proposed insufficient housing requirement. As
such, the GCLP as drafted will not meet the full objectively assessed need for housing contrary to the
requirements of paragraphs 11 and 23 of the NPPF.

Once the supply is assessed in accordance with national policy, the supply is actually lower than even
the proposed insufficient housing requirement.

Additionally, once the supply is assessed in accordance with national policy and even adopting the most
optimistic assumptions, there is not a sufficient supply of specific deliverable sites for five years following
the intended date of adoption contrary to the requirements of paragraph 72a of the NPPF.
As a consequence, the GCLP is unsound because:
i. It is not positively prepared as it does not provide a sufficient supply of housing to meet even the
proposed insufficient housing requirement, let alone reflect the economic ambitions of the government as
expressed through the Local Growth Plan.
ii. It will not be effective, as it will not meet housing needs or support local and national economic
ambitions, and in fact will actively constrain these objectives being achieved through the proposed
application of the Liverpool approach.
iii. It is inconsistent with national policy as it does not identify a sufficient supply to meet the
objectively assessed need for housing contrary to the requirements of paragraphs 11 and 23 of the
NPPF, and it does not identify a sufficient supply of specific deliverable sites for five years following the
intended date of adoption contrary to the requirements of paragraph 72a of the NPPF.
In terms of the Rest of the Rural Area, we note that this serves a very minor role in the chosen strategy
for this local plan. Figure 9 in the Plan highlights this fact with only 15% of the planned distribution of
growth in the rural area. As referred to in the Bidwells note appended to the Note on Housing Need and
Supply Matters, a strategy which relies too heavily on large allocations risks a lack of delivery in the first
10 years of the Plan due to the significant infrastructure required to service the very large allocations.
This problem is highlighted in paragraph 2.76 of the Plan where the text acknowledges that it must
‘ensure a deliverable plan but which is reliant on a significant level of infrastructure’. Senior Councillors at
Cabinet have also expressed their concerns to officers that this strategy is a risky one to adopt.
We consider this approach flawed as it heavily relies on two very large allocations set out under 2(c) i
Cambourne North (2550 dwellings in plan period) and 2(c) ii Grange Farm (2550 dwellings in the plan
period) which relies on significant infrastructure (namely Cambourne Railway Station to be delivered as
part of East West Rail and CSET respectively) coming forward in a timely manner to service these two
large strategic sites. Further ambiguity is compounded at paragraph 2.80 of the Plan to the strategy as
the Cambridge Wastewater Treatment Works still makes an appearance as a potential development site
even though Government funding for the project has been cancelled by Government.
Our view is that the local plan relies too heavily upon the strategic sites, which will not commence
delivery until the latter half of the plan, after 2035. The plan period is 2024-2045. Our view is that smaller
sites in sustainable settlement locations will be needed for housing delivery in the first 10 years of the
plan. If this does not happen the Plan is unlikely to have sufficient sites available to make up the shortfall
in delivery, as required by Government.

In particular, there are very few small and medium size housing sites allocated in the Rest of the Rural
Area. This lack of housing allocations in the rural area fails to support the delivery of homes to meet the
local housing needs of the next generation during the plan period. Instead of being able to live locally,
this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere
– often away from their existing family, community and support network. This leads to an increased need
for travel within Greater Cambridge, often via private cars rather than public transport. It also results in
population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the
new settlements have predominantly young populations and significant pressure on services.
To ensure the continued vitality of settlements across the Greater Cambridge rural area, an appropriate
degree of housing and employment growth is required to ensure economic footfall is placed into such
settlements and their respective highstreets, services and facilities. The NPPF (2024) explicitly requires Authorities to enable a sufficient amount of land to come forward for residential development to meet the
housing needs of the whole community - taking into account need, size, type and tenure (NPPF
paragraphs 61 – 63). To meet the needs of the whole Authority we contend a variety of land across the
Authority needs to be identified for development. In allocating the majority of proposed housing at new
settlements and new towns ignores the desire many may have within the Authority to live in the existing
settlements and villages located across the rural area. This further serves to reduce market competition
and choice, which is likely to have a detrimental impact on house prices and market availability.
A more balanced approach is required in respect to the Rural Area, including a wider range of housing
sites being allocated – in terms of both site sizes and locations. This is necessary to ensure that the
Local Plan supports sustainable communities and sustainable patterns of growth. The development
strategy should take account of the needs and vitality of existing villages and the wider rural economy,
making planned provision for them specifically.

In many villages, such as Harston, there is a lack of brownfield land available within the ‘defined
development extents’ to facilitate housing delivery in accordance with the approach set out in Draft Policy
S/SH (Settlement hierarchy). Also, small windfall sites provide limited affordable housing to meet local
needs. Hence, there should be specific land allocations for housing development in some of the rural
villages, to promote genuinely sustainable growth and development – supporting the rural economy,
promoting mixed and inclusive communities and ensuring the vitality and viability of local services.   

Furthermore, Paragraph 73 of the NPPF (2024) stresses the importance of the inclusion of medium and
small sized sites in order to meet the housing requirement of an Authority. They are also essential for
SME housebuilders to deliver new homes whilst being built out relatively quickly by virtue of the oftenminimal infrastructure requirements. The draft Local Plan does not propose to allocate any new housing
sites to address this requirement, the Evidence Base providing rationale for this that:
● It is challenging to identify a large number of small sites to meet the 10% requirement
● It would undermine the Council’s development strategy and necessitates the release of Green Belt
sites conflicting with the aim of protecting the Cambridge Green Belt as the larger and better served
villages are located within the Green Belt.

The Housing Delivery Addendum Update (2026) argues when accounting for windfall development of
4,953 dwellings coming forward on sites no larger than 1ha then 13.5% of homes over the plan period
will be delivered on small sites. Primarily relying upon windfall development to address as much of the
10% requirement as possible, does not help provide small and medium enterprise housebuilders with the
certainty required to invest in delivering sites. Across Greater Cambridge there has also been a general
decline in the delivery of windfall sites over the years. The Greater Cambridge Housing Delivery Study
Addendum Update (2026) in section 2 considers windfall delivery between 2006 and 2024 and consider
a windfall allowance for 425 dwelling per annum would be robust. This section of the report sets out what
it considers the favourable policy which may assist the delivery of windfall sites in the future. However, it
fails to identify why over time there has been a general trend downward on windfall sites, and whether in
reality, particularly in the South Cambridgeshire area there is now a lack of available sites to continue to
deliver windfall at scale across the plan period. For instance, it presents a data set as far back as 2006 –
2007 for windfall completions to find an average delivery rate of 470 dwellings per annum, fails to realise
that Greater Cambridge has not delivered more than 470 dwellings in a year from windfall since 2016 –
2017. Even if the Council uses 425 dwelling per annum for windfall over the previous seven years of data
the average delivery has been 395 dwellings per annum. As such, there needs to be greater certainty
injected into small and medium sized sites by allocating these in the emerging Local Plan, to aid with
confidence of being able to deliver such sites but also recognising that opportunities for brownfield
redevelopment or residential sub-division can only continue to deliver so much housing across Greater
Cambridge.

The focus upon large new settlements, urban redevelopment and Strategic Urban Extensions also fails
to properly consider the need to offer sufficient choice and flexibility to perspective homeowners. Not all
perspective purchasers will be able to, or wish to buy, in these locations. For instance, existing young
residents of village settlements in South Cambridgeshire may wish to buy a home in the settlement to be
close to existing family for childcare which may not be possible should they have to move to other
proposed allocations.

The proposed development strategy’s lack of commitment to delivering growth in sustainable settlements
in the rural area risks exacerbating the affordability crisis in Greater Cambridge, likely pushing younger
people out of their local communities and support networks. Reliance on strategic settlements outside of
the Green Belt (and hence further away from Cambridge) is also likely to increase car dependency.

In order to ensure that the best windfall Sites come forward to meet the target of 4,953 dwellings and are
of sufficient size to able to make a meaningful affordable housing contribution, we advocate for the
removal of the indicative maximum scheme size in Group Villages.

Jesus College object to Policy S/SH. The policy is unsound as it is not effective.

The indicative maximum scheme sizes are not considered to be necessary for the Group villages.
Windfall development that comes forward within these villages should be considered on the basis of the
site and its context. Schemes should be encouraged to make an efficient and effective use of land whilst
delivering housing development that is appropriate and helps in meeting the needs of the local
community. Often small windfall sites (under the thresholds indicated from Group and Infill Villages) will
provide limited or no affordable housing, exacerbating the situation for newly forming households who
cannot meet their housing needs locally.

Pertinent to ensuring the Plan is sound will require:
● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary
● The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

The Development Strategy Topic Paper (2026) states GCSP consider the identified need for 73,300 jobs
and 48,069 new homes across the plan period can be delivered without necessitating the allocation or
release of Green Belt land within the authority area. Notwithstanding given the fundamental changes to
National Policy introduced by the NPPF (2024), notably the introduction of grey belt, the Authority have
prepared and published a revised Greater Cambridge Green Belt Assessment – Review following
changes to National Policy and Guidance (2026) (‘the Green Belt Assessment (2026)’ prepared by LUC.
This is welcomed in principle.

Whilst the GCLP will be examined against the NPPF (2024) it should be noted that the relevant material
consideration for the determination of applications in terms of national policy will be the NPPF (2026).
Annex A (Paragraph 2) of the NPPF (2026) states that Development Plan polices which are materially
inconsistent with the national decision-making polices in the NPPF should be given very limited weight
for the purposes of decision-making. To ensure the GCLP is an effective mechanism for decisionmaking, particularly with regards to the Green Belt it is considered that GCSP should review the NDMPs
relevant to development in the Green Belt and update S/GB in full to reflect such position. Such policies
that are:
● GB6 (Control of development in the Green Belt)
● GB7 (Development which is not inappropriate in the Green Belt)
● GB8 (Golden rules)
It is considered the identified needs outlined above are too conservative and do not reflect the growth
agenda in national, regional and local contexts mandated by the incumbent Labour government. In line
with the Written Ministerial Statement made by Matthew Pennycook (Minister of State for Housing and
Planning) on 23 October 2025 the ambition remains to ‘supercharge growth’ within the OxfordCambridge Corridor and realise the full potential of Greater Cambridge. Furthermore, with the advent of
the Greater Cambridge Development Corporation (backed by £400 million of central government
funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor it is
expected an ambitious growth target will be identified; likely to exceed that currently envisioned by
GCSP. Collectively it remains apparent the government have a continued agenda to deliver high levels of
growth within Greater Cambridge and as such it is considered that GCSP will need to plan for a greater
level of growth as the Local Plan progresses.

Paragraph 146 (NPPF, 2024) (now Policy GB3[2]) identifies that one of the exceptional circumstances in
which Green Belt boundaries can be altered is where an authority cannot meet its identified need for
development in full, having examined other reasonable options. It is noted the Response to Development
Representations – Development Strategy Topic Paper (2026) and the Development Strategy Topic
Paper Appendix 5: Revised Greater Cambridge Local Plan Green Belt Review (2026) that the Authority
do not consider exceptional circumstances for a review of Green Belt boundaries to exist other than the
release of additional land at Cambridge Biomedical Campus (Phase 3) and at Babraham Research
Centre.

However, as identified through the enclosed Note on Housing Need and Supply Matters, Greater
Cambridge’s reliance on the Liverpool Method in calculating their Housing Land Supply runs a significant
risk of under delivery in the early years of the Plan. This is compounded by the Development Strategy’s
reliance on large strategic sites which given the extensive infrastructure requirements for such sites may
face delays to delivery. We raise concern that the reliance will lead to the unsustainable development
patterns and will not ensure a consistent, diverse and appropriate level of housing stock across the plan
period.

The NPPF (2024) is clear at paragraph 146 that exceptional circumstances are not just limited to where
an Authority cannot meet its identified needs in terms of quantum. As noted within our comments on the
Development Strategy, we consider that to ensure a consistent supply that meets the needs of the
Authority across the plan period Greater Cambridge need to consider the allocation of a diverse range of
sites well located to existing settlements to ensure both the longevity of existing settlements and that
growth is delivered and experienced across the Authority.

Paragraph 148 (NPPF, 2024) notes that strategic policy-making authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the
Green Belt boundary, towards towns and villages inset within the Green Belt boundary or towards
locations beyond the outer Green Belt boundary. In considering this, we advocate by virtue of many of
the rural settlements, such as Harston, that these are sustainable locations to facilitate further growth. As such, the Plan should consider the additional allocation of smaller sites on the edge of settlements inset
into the Green Belt to ensure the Development Strategy is sustainable and provides a robust, diverse
supply of housing across the Authority throughout the plan period.

Whilst the identification of the Cambridge grey belt within the ‘Cambridge Green Belt Assessment
Review following changes to National Policy and Guidance’ (2026) is welcomed, the omission of any
reference to ‘Grey Belt’ within Policy S/GB is questioned. The NPPF (2024) introduced a clear duty for
Grey Belt land to be identified when undertaking Green Belt Assessments for the purposes of
determining applications; reinforced within the Planning Practice Guidance (PPG) (Para 001 ref.001 64-
001-20250225). Hence, regardless of whether the Draft Local Plan can meet the identified needs for
growth without Green Belt release, the relevant Plan Policy (S/GB) should include explicit reference to
Grey Belt (consistent with the NPPF) and the identification of Grey Belt land within Greater Cambridge.
In considering the above, GCSP may also require a further Green Belt review and consider the additional
release of land from the Green Belt to accommodate sustainable and continued growth in the Authority
across the emerging plan period. This would ensure the emerging Local Plan is positively prepared,
justified, effective and consistent with national policy.

One such site that would be suitable to consider for Green Belt release is Land to the south of Station
Road, Harston (HELAA 2026 Ref: 115742). Harston is considered a suitable location for further
residential development to support an existing rural community. The site is considered to represent a
sustainable location for development which will help to meet the housing needs of Greater Cambridge in
Local Plan period.

The site itself forms a relatively small area of land within a much larger parcel identified in the Greater
Cambridge Green Belt Assessment (2021) (Parcel HS9) and development of the Site would comprise
limited infilling of a small gap between existing built development. The wider Parcel HS9 is identified in
the Greater Cambridge Green Belt Assessment (2021) as having either no/limited or moderate
contribution to the three Cambridge Green Belt purposes (and the corresponding NPPF Purposes (a), (b)
and (d)).

The Site therefore meets the NPPF definition of ‘grey belt’ on the grounds that it is land in the Green Belt
that does not does not ‘strongly contribute’ to any of purposes (a), (b), or (d) in paragraph 143.
As discussed below, Bidwells advocate that the Councils must include the identification of Grey Belt land
within the Draft Local Plan and as such the Site should be clearly identified as Grey Belt. Any future
residential development of the Site is also capable of meeting the ‘Golden Rules’ set out within
Paragraphs 156 - 157 of the NPPF.
Through the identification and allocation of Grey Belt sites across Greater Cambridge, such as Land to
the south of Station Road, Harston, pressures on green space within villages can be alleviated.
Furthermore, the allocation of Grey Belt sites can ensure a spatial strategy with the most sustainable
locations developed first and where the local need can be met in those villages where it has been
identified that existing services and facilities provide a sustainable opportunity for further development.
The area of Grey Belt identified within this submission would support a modest rollback of the Green
Belt, to better reflect the contemporary shape and form of Harston.

As referred to above, the identification of the Cambridge grey belt within the Cambridge Green Belt
Assessment Review following changes to National Policy and Guidance (2026) is welcomed, however
Bidwells object to aspects of the methodology used, in particular the identification of both a ‘moderate’ or
‘weak’ contribution to NPPF purpose D. The definition of grey belt as found within the NPPF (2026) does
not set out such a distinction. Rather the glossary of the NPPF confirms grey belt is solely land in the
Green Belt that ‘does not strongly contribute to any of purposes a.), b.) and d.) in policy GB2’. As such it
is considered unnecessary for the Authority to distinguish between ‘moderate’ and ‘weak’ in relation to identifying grey belt and instead should remove such distinction to identify one consistent grey belt for
Greater Cambridge. This would ensure the Evidence Base on which the GCLP is built upon would be
consistent with national policy.