Greater Cambridge Local Plan: Proposed Submission

To address these concerns and improve NPPF compliance, the following modifications are required:
● remove the requirement for affordable workspace to be secured in perpetuity and replace it with a
time-limited or viability-informed approach;
● make affordable workspace provision subject to viability assessment in all circumstances;
● review and increase the proposed 1,000sqm office and R&D threshold;
● introduce greater locational flexibility to reflect differing commercial market conditions across Greater
Cambridge;
● undertake further viability testing using realistic market assumptions and testing the policy as drafted;
● undertake a comprehensive cumulative-impact assessment covering all Local Plan obligations and
the emerging CIL regime; and
● incorporate review mechanisms so requirements can adapt to changing market conditions over the
Plan period.
For the reasons above, and having regard to the accompanying viability evidence, Policy J/AW has not
been shown to be positively prepared, justified, effective or consistent with national policy as required by
paragraph 36 of the NPPF. The evidence does not demonstrate that the affordable workspace
obligations can be delivered without prejudicing the viability and delivery of employment development
central to the Greater Cambridge economy. The policy should therefore be significantly modified or
deleted.

Jesus College object to Policy J/AW. It is not sound as it is not positively prepared, justified, effective or
consistent with national policy.
While the objective of increasing affordable workspace in Greater Cambridge is supported in principle,
draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been
shown to be positively prepared, justified, effective or consistent with national policy and should therefore
be substantially revised or deleted. This objection should be read with the accompanying Bidwells
Viability Representation, which identifies significant shortcomings in the Councils’ evidence base.

Assessment of Whether the Policy is Justified

Paragraph 36 of the NPPF (2024) requires Local Plans to be justified, meaning they must represent an
appropriate strategy, consider reasonable alternatives and be based on proportionate evidence.
The Councils have not demonstrated that Policy J/AW is the most appropriate strategy for increasing the
amount of commercial floorspace affordable and available.
Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most
onerous requirements, including:
● 10% affordable workspace across a broad range of commercial development types;
● rental discounts of up to 30% below market rents;
● affordable provision secured in perpetuity;
● the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
● a largely uniform approach across materially different commercial markets.
The Iceni Affordable Workspace Study (2026), which forms part of the Evidence Base, acknowledges
that comparable policies vary widely in thresholds, discounts and affordability periods, but does not
explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives,
including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led
mechanisms, do not appear to have been robustly assessed or discounted.
The Affordable Workspace Study relies heavily on London comparators, including Southwark, Brent,
Waltham Forest and Wandsworth, and the draft policy appears consistent with Lambeth and
Westminster approaches. This is flawed because London’s market, economic and geographic conditions iffer significantly from Greater Cambridge, particularly South Cambridgeshire’s dispersed, rural and
science-park-led economy. Oxford, the only non-London reference point, concerns Community
Employment and Procurement Plans rather than affordable workspace. The read-across to Greater
Cambridge has therefore not been adequately evidenced.
Oxford City Council’s Regulation 19 Proposed Submission Local Plan includes draft Policy E4
(Affordable Workspaces), which requires:
● development proposals delivering a net gain of 5,000sqm GIA of employment uses (E-Class) to
produce an affordable workspace strategy for specified sites; and
● the strategy to set out the details, size, marketing, servicing, management and delivery of the space.
Oxford’s approach is more flexible and site-specific, enabling affordable workspace where justified by
need and deliverability. Given Oxford’s strong R&D sector and similar affordability pressures for SMEs, it
is more comparable to Greater Cambridge than the London examples. A more justified approach would
therefore align more closely with Oxford’s emerging policy.
We acknowledge Oxford’s emerging Local Plan has not been examined yet and hence the policy has not
yet been demonstrated to be sound yet. Nonetheless we contend this indicates a flexible, market led
approach in a comparable context to Greater Cambridge, facing similar issues with regards to University
spin outs, SME’s and supply and demand of commercial floorspace.
The in-perpetuity requirement is unjustified. The evidence recognises that comparable policies often use
fixed periods yet gives no compelling reason for a permanent restriction in Greater Cambridge. A
perpetual discount permanently suppresses rental income and investment value, unlike a time-limited
obligation. Lambeth’s policy, for example, expires after 15 years.
The basis for reducing the office and R&D threshold to 1,000sqm is unclear. The evidence relies
substantially on London benchmarking, which does not reflect Greater Cambridge’s dispersed science
park, innovation campus and rural employment locations. The threshold therefore lacks a robust local
evidential basis.
We also raise concern that the 1,000sqm threshold is arbitrary and risks creating a cliff-edge for
development required to provide affordable workspace. We recommend a transitional and graduated
approach should be introduced rather than a square cut off at 1,000sqm which may discourage
developers from pursuing schemes which may trigger the 1,000sqm threshold but do not benefit from the
economies of scale large and strategic schemes do which may be better placed to absorb affordable
workspace requirements.
Policy J/AW has therefore not been shown to represent the most appropriate strategy or to be supported
by proportionate evidence. It is not justified under paragraph 36 of the NPPF (2024).

Assessment of Whether the Policy is Effective

Paragraph 36 of the NPPF (2024) requires Local Plan policies to be effective and deliverable over the
plan period.

The Councils have not shown that Policy J/AW can be delivered without harming the employment
development needed to support Greater Cambridge’s growth ambitions.
Policy J/AW would also sit alongside biodiversity net gain, net-zero carbon requirements, transport
mitigation, open space, green infrastructure, Section 106 contributions and the emerging Community
Infrastructure Levy regime.
Although some requirements have been assessed individually, the evidence does not convincingly
demonstrate that commercial development can absorb the cumulative cost of Local Plan and regulatory
obligations across the Plan area.
This is particularly important in current market conditions. Greater Cambridge’s office, laboratory and life
sciences sectors are undergoing market adjustment, as set out in the Viability Representation prepared
by Bidwells. The Councils’ evidence acknowledges changing occupier demand, increased laboratory
vacancy, financing pressures and economic uncertainty. In this context, any policy that permanently
reduces investment returns risks suppressing development activity and undermining delivery.
The viability representation identifies substantial concerns with the Local Plan Viability Assessment,
including assumptions on rents, yields, benchmark land values, build costs, developer return and
brownfield redevelopment costs. These concerns call into question the robustness of the viability and
deliverability conclusions.
The Councils have therefore not shown that the policy will be deliverable across the commercial
schemes to which it would apply. There remains a significant risk that it will reduce delivery of office,
R&D, laboratory and industrial floorspace during the Plan period.
It should be noted that this requirement is being introduced at the same time as Employment and Skills
Plans which we support. We consider this mechanism to be an effective, meaningful way to help
individuals in the employment market. In comparison we query the overall effectiveness of affordable
workspace provisions on individuals in the job market.
As drafted, the policy risks threatening commercial viability and reducing investment in Greater
Cambridge. Contrary to its aim, it could reduce overall affordable workspace provision. The policy is
therefore not effective.

Assessment of Whether the Policy is Consistent with National Policy

Chapter 6 of the NPPF (2024) promotes a strong, competitive economy. Paragraph 85 requires planning
policies to give significant weight to economic growth and to maintain conditions for investment and
sustainable development.
The NPPF also makes clear that planning policies should not undermine viability or impose burdens that
threaten delivery.
Policy J/AW is inflexible and does not adequately respond to changing market conditions. Its affordable
workspace requirement, discount levels and affordability period are fixed, with viability considerations
focused mainly on payment in lieu rather than the principle of provision. This rigidity is inconsistent with
the NPPF’s emphasis on delivery, flexibility and maintaining viability.
The Councils have not justified why an in-perpetuity requirement is necessary, or why the policy should
apply unchanged regardless of future economic, occupational or investment conditions. Commercial
markets fluctuate, and policy must be able to respond.
Without robust evidence that the requirements can be absorbed without harming delivery, the policy is
not consistent with national objectives for economic growth, productivity and investment.

Assessment of Whether the Policy has been Positively Prepared

The Local Plan must be positively prepared and provide a strategy capable of meeting identified needs,
in accordance with paragraph 36a of the NPPF.
Greater Cambridge’s economic success depends on continued employment floorspace delivery and its
global strength in life sciences, R&D, biomedical and IT sectors. The growth strategy relies on offices,
laboratories, innovation space and industrial accommodation across a range of locations.
Although Policy J/AW seeks to address affordable workspace need, it risks undermining the wider
commercial floorspace delivery on which economic growth depends, given the concerns in the Viability
Representation. Additional obligations may reduce investment, delay delivery and discourage
employment-land redevelopment, particularly on constrained brownfield sites affected by contamination
and remediation costs.
If the policy reduces overall commercial development delivery, it would frustrate rather than support the
Plan’s wider economic objectives and cannot reasonably be regarded as positively prepared.

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 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 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 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 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.

The Important Countryside Frontage designation affecting land south of Station Road, Harston should be removed.

Jesus College object to Policy GP/LC. The policy is unsound as it is not justified.
Part 2 of the Policy states that “Important Countryside Frontages (ICFs) are identified on the Policies
Map and are in villages where land with a strong countryside character either:
a. Penetrates or sweeps into the built-up area providing a significant connection between the built
environment and the surrounding rural area; and
b. Provides an important rural break between two nearby but detached parts of a defined development
extent.”

Part 3 of the Policy then states that “Planning permission for development will be refused if it would
compromise these ICF purposes.”

An extract of the Policies Map as it relates to Land south of Station Road, Harston is shown in the attached representation letter.

Jesus College do not consider the Important Countryside Frontage designation to the south of Station
Road in Harston is justified. The existing two-metre tall evergreen hedge along the length of the Station
Road frontage can be retained and managed as part of any development proposal, with the exception of
two small sections to be removed in order to accommodate access. This hedge already acts as a natural
barrier to the countryside frontage and the loose grain of development and low density proposed will also
enable views of the open countryside beyond to be retained from Station Road. As such, residential
development on Land to the south of Station Road, Harston could be brought forward without
compromising the purposes of Important Countryside Frontages, in terms of ‘providing a significant
connection between the built environment and the surrounding rural area’ and ‘providing an important
rural break’.

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will
be necessary to utilise more optimistic and realistic figures for job and housing numbers and include
explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound
and inconsistent with national policy objectives to support sustainable economic growth and productivity.

Jesus College object to Policy S/DS: Development Strategy. The policy is unsound as it is not consistent
with national policy.
As referred to in representations to Policy S/JH, the identified needs in the Plan are considered too
conservative and do not reflect the growth agenda in national, regional and local contexts mandated by
the incumbent Labour Government. 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. Collectively, it remains apparent therefore that the Government have a continued
agenda to deliver high levels of growth within Greater Cambridge and as such more optimistic and
realistic figures for job and housing numbers are needed to support sustainable economic growth and
productivity.
Furthermore, the development strategy relies too heavily on large allocations which in turn 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.
In particular, the Plan 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.

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will
be necessary to utilise more optimistic and realistic figures for job and housing numbers and include
explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound
and inconsistent with national policy objectives to support sustainable economic growth and productivity.

Jesus College object to Policy S/DS: Development Strategy. The policy is unsound as it is not consistent
with national policy.
As referred to in representations to Policy S/JH, the identified needs in the Plan are considered too
conservative and do not reflect the growth agenda in national, regional and local contexts mandated by
the incumbent Labour Government. 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. Collectively, it remains apparent therefore that the Government have a continued
agenda to deliver high levels of growth within Greater Cambridge and as such more optimistic and
realistic figures for job and housing numbers are needed to support sustainable economic growth and
productivity.
Furthermore, the development strategy relies too heavily on large allocations which in turn 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.
In particular, the Plan 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.

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will
be necessary to utilise more optimistic and realistic figures for job and housing numbers and include
explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound
and inconsistent with national policy objectives to support sustainable economic growth and productivity.

Jesus College object to Policy S/DS: Development Strategy. The policy is unsound as it is not consistent
with national policy.
As referred to in representations to Policy S/JH, the identified needs in the Plan are considered too
conservative and do not reflect the growth agenda in national, regional and local contexts mandated by
the incumbent Labour Government. 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. Collectively, it remains apparent therefore that the Government have a continued
agenda to deliver high levels of growth within Greater Cambridge and as such more optimistic and
realistic figures for job and housing numbers are needed to support sustainable economic growth and
productivity.
Furthermore, the development strategy relies too heavily on large allocations which in turn 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.
In particular, the Plan 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.