Greater Cambridge Local Plan: Proposed Submission

Our client would draw attention to their previous recommendation: that if the policy is to retain a section setting out the housing requirement for neighbourhood areas, then an additional section should be added to include provision for housing in areas that are not neighbourhood plan areas. This could set out projected growth in other villages within the hierarchy and offer a greater structure to growth across the district.
We would request that the policy includes provision for growth in the village of Great Abington, a location that is not a designated neighbourhood area, and that the level of growth is proportionate to the existing settlement and responds to the availability of suitable sites.

Comment -
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/JH for the following reasons:
Policy S/JH should be read in conjunction with Policy S/DS, to which our clients have also objected. The two policies are clearly interlinked and provide the overarching policy structure for future growth in the Greater Cambridge area.
Our client wishes to reiterate their previous objection that while there is support for the objectives of the policy to deliver the objectively assessed housing need, given the scale of the new homes required at a minimum of 48,069 new homes, the proposed distribution of this growth and the over-reliance on large sites will undoubtedly result in a failure to deliver the step change in housing supply required by the NPPF, particularly in the short and medium term. This continues a trend within Greater Cambridgeshire that has stifled growth across the wider district to the detriment of those communities.
48,069 dwellings is the requirement, and Table 1 shows a supply of 52,032, which is 8.2% headroom; however, at least 10% is the usual target.
Fig. 9/page 54 shows that 44% of supply in the GCLP is on New Settlements compared to 23% in the current adopted plans. This is a significant shift in strategy that has a higher risk of delay in delivery due to complex sites, the need for major infrastructure where funding is not certain and notoriously long lead-in times. In addition, as noted in paragraphs 2.57-9 and 2,77-81 the issues associated with Water and wastewater infrastructure potentially delaying delivery on big sites in Cambridge. Therefore, it can be argued that a modification should include a higher housing requirement.
Policy S/JH is identified as one of the Local Plan's strategic policies. The whole strategy is based upon balancing jobs and homes across Greater Cambridge. However, substantial employment growth is proposed around Babraham Research Campus, Wellcome Genome Campus, Granta Park and the wider Southern Cluster; whilst the sustainable settlement of Great Abington receives no allocation despite lying immediately adjacent to these employment locations.
This approach is not consistent with NPPF Policy E1, which states:
1. To support business investment and employment, development plans should, at the most appropriate level:
b. Seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment; and
In support of our observations , we include a Socio Economic Benefits Statement prepared by Pegasus in support of a recent appeal at Land north of Pampisford Road, Great Abington. The reports highlights the following important points:
• Extensive evidence exists that the availability and affordability of housing in South Cambridgeshire is a barrier to the growth targeted by the adopted and emerging Local Plans. The range of types and tenures of homes proposed at the site are ideally aligned to the variety of incomes of those working within growth sectors, meaning that they will directly support this growth by alleviating housing pressures. If sufficient housing is not delivered the growth opportunity in areas such as life sciences will be lost to the UK and captured overseas.
• As policy identifies, local services are also critical in support of homes and jobs. A range of local health, education and community service providers are in close proximity to the site. These types of public employers currently struggle with retention and recruitment of staff, with housing typically being the largest single factor. As demonstrated within this report, the mix of market, intermediate and social / affordable rent homes means that a wide range of local keyworkers could afford to live at the site and support the delivery of local public services.
Finally, noting that the Council’s have recently changed the way they are calculating their trajectories, moving from joint to individual supply calculations, our client would suggest that the housing and employment needs for each local authority area should be split up and made clear how they relate to each authority area.
Soundness -
The Plan is inconsistent with Policy S/JH because it plans for significant employment growth in the Southern Cluster but fails to allocate sufficient housing in nearby sustainable settlements capable of supporting that growth in the short to medium term.
In conclusion, Policy S/JH will exacerbate the delays in the delivery of housing and for that reason this policy is not appropriate, as it is not the appropriate strategy taking into account the alternatives; is not positive, as it fails to take proactive steps towards addressing need in the short to medium term; not consistent with national policy and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to Policies HO3 and E1(1)(b) of the NPPF.

Furthermore, and linked to the above our client wishes to make the following comments on Appendices D and E:

Appendix D:
Appendix D relies upon a Greater Cambridge-wide housing trajectory and five-year housing land supply assessment, notwithstanding the authorities' recent decision to calculate housing supply separately on the basis that the HDT results are currently being published separately.
The Greater Cambridge Authorities were previously calculating their supply jointly but, following the publication of the NPPF 2026 and the latest HDT results, they decided that the calculation should be done separately. It is therefore a concern that the joint calculation may fail to demonstrate that housing delivery can be maintained within each constituent authority area, relying upon an evidence base that no longer reflects the authorities' current monitoring and implementation framework.
Separate calculations clearly produce materially different outcomes, where one authority may have a weaker housing supply position than the joint figure suggests, as is currently the case in respect of Cambridge City. This joint trajectory can therefore mask actual delivery risks.
The question my client wishes to raise is whether, given the recent change to the joint calculation that has occurred during the Regulation 19 consultation, an updated calculation will be provided that demonstrates that both authorities will be able to demonstrate a 5 year supply of housing sites at the point of adoption?
My client has limited confidence in the long-term reliability of a joint approach to assessing housing provision, particularly in light of the authorities' repeated changes in position regarding the methodology for calculating housing supply and delivery.
Furthermore, D.4 states that the calculation includes for a 5% buffer base don the anticipated HDT results. This statement is now out of date, and given the recent HDT results require Cambridge City to use a 20% buffer, our client contends that a 20% buffer should be applied to the Cambridge City requirement.

Appendix E:
The proposed Monitoring Framework does not work if the Councils are to split the calculation and make it clear what each authority must provide for during the plan period. Please refer to our objections to policies S/JH and S/DS and Appendix D.

Amend Policy S/DS and the associated site allocation provisions to recognise Great Abington as a sustainable location capable of accommodating modest residential growth and allocate site(s) for development.

Comment
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/DS for the following reasons:
Policy S/DS should be read in conjunction with Policy S/JH, to which our clients have also objected. The two policies are clearly interlinked and provide the overarching policy structure for future growth in the Greater Cambridge area.
Our clients would reiterate the argument that the proposed Development Strategy remains over reliant on large scale allocations. There is a failure to consider the need to distribute growth more proportionally across a range of sites throughout Greater Cambridge. The significant reliance on large scale allocations to deliver housing numbers is a risky strategy when compared to the alternatives, because such sites take longer to set up and start delivering new homes. Should this occur, it will be very difficult to maintain the delivery rates as set out in the LPAs housing trajectory in the short to medium term where there is already an over reliance on the existing new settlements delivering housing at the very optimum level every single year without fail.
NPPF Policy HO6: Planning for a diverse mix of sites states:
1. To support the provision of a diverse mix of sites, local plans should:
a. Allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites of between one and two and a half hectares, unless there are strong reasons why these targets cannot be achieved; and
b. Allocate sites which will support and enhance the vitality of rural communities and enable villages to grow and thrive, especially where this will support local services.
This carries through the previous requirements of paragraph 73 of the NPPF 2024, which noted that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, are essential for Small and Medium Enterprise housebuilders to deliver new homes and are often built out relatively quickly.
The plan is clearly failing to do this as set out in paragraphs 2.41-2.43. The plan only proposes allocations for 4.2%, arguing this is appropriate for Greater Cambridge as they would have to identify lots of rural sites and compromise their sustainability strategy. This justification is weak, and directly contravenes the NPPF and its purpose.
By including a greater number of small and medium size sites in the development strategy there is a better chance of the strategy meeting the housing needs, particularly in the short to medium term, and reducing the risk of the LPA falling below its’s 5-year land supply requirement. We would contend that the Development Strategy should be amended to support a more proportional distribution of growth across Greater Cambridgeshire so that all areas can benefit from growth which will contribute towards the vitality and viability of existing services.
For example, Great Abington is a sustainable settlement, sitting at the heart of the Rural Southern Cluster adjacent to major business park and employment area of Granta Park, but it is not designated a Neighbourhood Plan Area and therefore does not have a Neighbourhood Plan in place, nor has one been advanced. The Former Land Settlement Association Estate is designated and has an adopted Neighbourhood Plan, and the housing requirement in Appendix D is only for 5 dwellings. The key issue is that there is no mechanism for growth, which is essential for maintaining the vitality and viability of the existing settlement.
The allocation of Grange Farm New Settlement will no doubt be argued as addressing the needs of the neighbouring settlements, but that is the long-term prognosis, not the short or medium term, with the new settlement likely to take 7 to 10 years to start delivering the new homes needed to support the continued growth of employment at places like Granta Park and the Babraham Research Campus. Reliance upon Grange Farm carries significant risks, as it remains unclear from the evidence that the site is deliverable or viable.
Ultimately, policy S/DS states that development should be directed to locations where:
• active travel and public transport are realistic alternatives to the private car;
• jobs, services and facilities are accessible;
• development contributes towards sustainable patterns of growth.
However, the Plan does not allocate land at Great Abington despite its proximity to:
• Babraham Research Campus;
• Wellcome Genome Campus;
• Granta Park;
• the A1307 transport corridor;
• proposed active travel and public transport improvements serving the Rural Southern Cluster.
There is also the potential for there to be in imbalance between jobs and homes, as the Plan allocates substantial employment growth within the Rural Southern Cluster whilst directing relatively little housing growth to neighbouring villages.
This creates a disconnect between:
• housing locations; and
• employment locations.
As a consequence, workers employed at:
• Granta Park;
• Babraham Research Campus;
• Wellcome Genome Campus;
may be required to travel greater distances to access housing, which is contrary to the objectives of Policy S/DS which seek sustainable patterns of development and reduced travel demand.
Our clients believe the omission of Great Abington is inconsistent with the fundamental aims of Policy S/DS because the village performs strongly against the very sustainability indicators that underpin the development strategy.
The combination of Policy S/DS and Policy S/SH results in an insufficiently flexible housing strategy which directs substantial growth towards strategic developments whilst limiting sustainable villages such as Great Abington to very modest windfall growth.
Even accepting Great Abington's status as a Group Village, the Plan should allocate a site because allocations are expressly treated differently from windfall development under Policy S/SH and paragraph 2.115, which confirms that allocated sites may exceed the normal settlement hierarchy limits where justified as part of the wider development strategy. The Group Village status is therefore not a reason to exclude an allocation.
Soundness
In conclusion, Policy S/DS will exacerbate the delays in the delivery of housing, and for that reason this policy is not appropriate, as it is not the appropriate strategy taking into account the alternatives; is not positive, as it fails to take proactive steps towards addressing need in the short to medium term; is NOT consistent with national policy; and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to Policies HO3 and HO6 of the NPPF.

Review the settlement hierarchy assessment and consider whether Great Abington should accommodate a specific allocation as a sustainable growth location rather than relying solely on windfall development.

Comment
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/SH for the following reasons:
Policy S/SH classifies Great Abington as a Group Village, where growth is primarily expected to come through windfall development, generally limited to around eight dwellings and exceptionally fifteen dwellings on brownfield land.
This classification is difficult to reconcile with the village's strategic location within the Rural Southern Cluster and its proximity to nationally significant employment centres.
As previously highlighted, this policy does not positively support growth in sustainable locations. The range of services and facilities across the ‘Group Villages’ varies, particularly in respect of access to jobs and employment. Great Abington has the benefit of close proximity to Granta Park, as well as sustainable transport links to a secondary school and medical facilities. The limitation being applied is too generalised and does not recognise the unique individual merits of certain locations.
The evidence supporting the settlement hierarchy appears to place insufficient weight on:
• employment accessibility;
• sustainable transport opportunities;
• the village's role in supporting the Southern Cluster economy.
This is particularly significant given that other settlements performing comparable functions are expected to accommodate planned growth.
The plan places the emphasis on the role of Grange Farm, new settlement policy Policy S/GF. However, this settlement will take some time to start delivering housing and support job creation at Granta Park. Smaller and medium-sized allocations, in Great Abington, would contribute towards much earlier delivery, addressing housing need in the short term.
Soundness
In conclusion, Policy S/SH is not appropriate, as it is not the appropriate strategy taking into account the alternatives; is not positive, as it fails to take proactive steps towards addressing need in the short to medium term; is NOT consistent with national policy; and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to Policy HO3 of the NPPF.

The Council is encouraged to revisit the assessment of Development Extents and to consider adjustments to facilitate growth, or preferably to allocate additional development. As we have highlighted, this policy is designed to constrain growth, contrary to the objectives of the Settlement Hierarchy policies, which imply that growth is possible. We would recommend that the Council provide an independent policy structure that allows for sustainable growth beyond the Development Extents, where a site adjoins the settlement.

Comment
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/DE for the following reasons:
We must reiterate the previous objection to this policy in conjunction with our client’s objection to policy S/JH. The policy does not facilitate development outside of a Defined Development Extent unless it is allocated within a Neighbourhood Plan or meets a very narrow range of exceptions.
As we stated in our objections to policy S/JH, we would contend that the plan should not rely upon Neighbourhood Plans coming forward, as this limits growth to those areas that have been designated and are bringing forward or are reviewing an existing Neighbourhood Plan. This limits the geographical location and range of sites that can be delivered through this approach. We would argue the plan fails to tackle this issue directly by leading through example and would recommend that the plan directly allocate more smaller and medium-sized sites, especially where there is no Neighbourhood Plan. Furthermore, the Planning Practice Guidance makes clear that housing requirements for designated neighbourhood areas cannot be binding, as Neighbourhood Plans are not required to plan for housing.
Development Extents are usually very tightly drawn around existing settlements, leaving very little room for growth within the settlement itself, so when coupled with the limitations of growth within the Settlement Hierarchy under Policy S/SH, the policy leaves little scope for development on suitable small and medium-sized sites on the edge of existing settlements. This constraint undermines the positive contribution such sites can make to the proportional growth of villages, which will help to maintain the viability of existing services.
Soundness
In conclusion, Policy S/DE is not appropriate, as it is not the appropriate strategy taking into account the alternatives; is not positive, as it fails to take proactive steps towards addressing need in the short to medium term; is NOT consistent with national policy; and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to Policy HO3 of the NPPF.

This is a comment to be read in conjunction with our client's objections.

Comment
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to COMMENT on Policy H/AH as follows:
Policy H/AH requires 40% affordable housing on major residential developments. Greater Cambridge has a substantial affordable housing shortfall, including identified unmet need in Great Abington. Without sufficient planned allocations in areas of need, the policy will not be effective.
A specific allocation at Great Abington would secure affordable housing where it is needed, whereas the small-scale windfall development envisaged by Policy S/SH is unlikely to deliver an equivalent contribution.
While Policy H/ES: Exception Sites for Affordable Housing, seeks to provide a mechanism to deliver affordable housing as an exception in villages such as Great Abington, reliance on Policy H/ES and small windfall opportunities is not a substitute for a planned allocation where a village is capable of accommodating sustainable growth and contributing to strategic housing delivery.
Failure to allocate a site represents a missed opportunity.

This is a comment to be read in conjunction with our client's objections to the plan.

Comment
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to COMMENT on Policy I/ST as follows:
Proposed policy I/ST requires development to:
• support walking;
• cycling;
• public transport;
• access to employment centres;
• sustainable movement patterns.
Our client would argue that the spatial strategy is not making full use of locations capable of supporting Policy I/ST objectives. Our client is promoting land in Great Abington, which, while identified as a Group Village, is a highly sustainable location in close proximity to several employment areas identified for growth. Great Abington sits within the A1307 corridor and is closely related to:
• Cambridge South East Transport proposals;
• Southern Cluster employment areas;
• active travel improvements.
Despite this, the strategy does not take the opportunity to allocate development to Great Abington, relying solely on the new settlement of Grange Farm, a site that is unlikely to deliver in the short and medium term. This increases the risk of the spatial strategy failing.

Amend the site allocation provisions to recognise Great Abington as a sustainable location capable of accommodating modest residential growth and allocate site(s) for development.

Comment
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to COMMENT on Policy H/AH as follows:
Policy H/AH requires 40% affordable housing on major residential developments. Greater Cambridge has a substantial affordable housing shortfall, including identified unmet need in Great Abington. Without sufficient planned allocations in areas of need, the policy will not be effective.
A specific allocation at Great Abington would secure affordable housing where it is needed, whereas the small-scale windfall development envisaged by Policy S/SH is unlikely to deliver an equivalent contribution.
While Policy H/ES: Exception Sites for Affordable Housing, seeks to provide a mechanism to deliver affordable housing as an exception in villages such as Great Abington, reliance on Policy H/ES and small windfall opportunities is not a substitute for a planned allocation where a village is capable of accommodating sustainable growth and contributing to strategic housing delivery.
Failure to allocate a site represents a missed opportunity.

They request updated evidence confirming that each authority can demonstrate a five-year housing land supply at adoption, with the required 20% buffer applied to Cambridge City.

Comment -
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/JH for the following reasons:
Policy S/JH should be read in conjunction with Policy S/DS, to which our clients have also objected. The two policies are clearly interlinked and provide the overarching policy structure for future growth in the Greater Cambridge area.
Our client wishes to reiterate their previous objection that while there is support for the objectives of the policy to deliver the objectively assessed housing need, given the scale of the new homes required at a minimum of 48,069 new homes, the proposed distribution of this growth and the over-reliance on large sites will undoubtedly result in a failure to deliver the step change in housing supply required by the NPPF, particularly in the short and medium term. This continues a trend within Greater Cambridgeshire that has stifled growth across the wider district to the detriment of those communities.
48,069 dwellings is the requirement, and Table 1 shows a supply of 52,032, which is 8.2% headroom; however, at least 10% is the usual target.
Fig. 9/page 54 shows that 44% of supply in the GCLP is on New Settlements compared to 23% in the current adopted plans. This is a significant shift in strategy that has a higher risk of delay in delivery due to complex sites, the need for major infrastructure where funding is not certain and notoriously long lead-in times. In addition, as noted in paragraphs 2.57-9 and 2,77-81 the issues associated with Water and wastewater infrastructure potentially delaying delivery on big sites in Cambridge. Therefore, it can be argued that a modification should include a higher housing requirement.
Policy S/JH is identified as one of the Local Plan's strategic policies. The whole strategy is based upon balancing jobs and homes across Greater Cambridge. However, substantial employment growth is proposed around Babraham Research Campus, Wellcome Genome Campus, Granta Park and the wider Southern Cluster; whilst the sustainable settlement of Great Abington receives no allocation despite lying immediately adjacent to these employment locations.
This approach is not consistent with NPPF Policy E1, which states:
1. To support business investment and employment, development plans should, at the most appropriate level:
b. Seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment; and
In support of our observations , we include a Socio Economic Benefits Statement prepared by Pegasus in support of a recent appeal at Land north of Pampisford Road, Great Abington. The reports highlights the following important points:
• Extensive evidence exists that the availability and affordability of housing in South Cambridgeshire is a barrier to the growth targeted by the adopted and emerging Local Plans. The range of types and tenures of homes proposed at the site are ideally aligned to the variety of incomes of those working within growth sectors, meaning that they will directly support this growth by alleviating housing pressures. If sufficient housing is not delivered the growth opportunity in areas such as life sciences will be lost to the UK and captured overseas.
• As policy identifies, local services are also critical in support of homes and jobs. A range of local health, education and community service providers are in close proximity to the site. These types of public employers currently struggle with retention and recruitment of staff, with housing typically being the largest single factor. As demonstrated within this report, the mix of market, intermediate and social / affordable rent homes means that a wide range of local keyworkers could afford to live at the site and support the delivery of local public services.
Finally, noting that the Council’s have recently changed the way they are calculating their trajectories, moving from joint to individual supply calculations, our client would suggest that the housing and employment needs for each local authority area should be split up and made clear how they relate to each authority area.
Soundness -
The Plan is inconsistent with Policy S/JH because it plans for significant employment growth in the Southern Cluster but fails to allocate sufficient housing in nearby sustainable settlements capable of supporting that growth in the short to medium term.
In conclusion, Policy S/JH will exacerbate the delays in the delivery of housing and for that reason this policy is not appropriate, as it is not the appropriate strategy taking into account the alternatives; is not positive, as it fails to take proactive steps towards addressing need in the short to medium term; not consistent with national policy and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to Policies HO3 and E1(1)(b) of the NPPF.

Furthermore, and linked to the above our client wishes to make the following comments on Appendices D and E:

Appendix D:
Appendix D relies upon a Greater Cambridge-wide housing trajectory and five-year housing land supply assessment, notwithstanding the authorities' recent decision to calculate housing supply separately on the basis that the HDT results are currently being published separately.
The Greater Cambridge Authorities were previously calculating their supply jointly but, following the publication of the NPPF 2026 and the latest HDT results, they decided that the calculation should be done separately. It is therefore a concern that the joint calculation may fail to demonstrate that housing delivery can be maintained within each constituent authority area, relying upon an evidence base that no longer reflects the authorities' current monitoring and implementation framework.
Separate calculations clearly produce materially different outcomes, where one authority may have a weaker housing supply position than the joint figure suggests, as is currently the case in respect of Cambridge City. This joint trajectory can therefore mask actual delivery risks.
The question my client wishes to raise is whether, given the recent change to the joint calculation that has occurred during the Regulation 19 consultation, an updated calculation will be provided that demonstrates that both authorities will be able to demonstrate a 5 year supply of housing sites at the point of adoption?
My client has limited confidence in the long-term reliability of a joint approach to assessing housing provision, particularly in light of the authorities' repeated changes in position regarding the methodology for calculating housing supply and delivery.
Furthermore, D.4 states that the calculation includes for a 5% buffer base don the anticipated HDT results. This statement is now out of date, and given the recent HDT results require Cambridge City to use a 20% buffer, our client contends that a 20% buffer should be applied to the Cambridge City requirement.

Appendix E:
The proposed Monitoring Framework does not work if the Councils are to split the calculation and make it clear what each authority must provide for during the plan period. Please refer to our objections to policies S/JH and S/DS and Appendix D.

Appendix E’s monitoring framework should also be revised to reflect separate housing requirements and supply calculations.

Comment -
We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/JH for the following reasons:
Policy S/JH should be read in conjunction with Policy S/DS, to which our clients have also objected. The two policies are clearly interlinked and provide the overarching policy structure for future growth in the Greater Cambridge area.
Our client wishes to reiterate their previous objection that while there is support for the objectives of the policy to deliver the objectively assessed housing need, given the scale of the new homes required at a minimum of 48,069 new homes, the proposed distribution of this growth and the over-reliance on large sites will undoubtedly result in a failure to deliver the step change in housing supply required by the NPPF, particularly in the short and medium term. This continues a trend within Greater Cambridgeshire that has stifled growth across the wider district to the detriment of those communities.
48,069 dwellings is the requirement, and Table 1 shows a supply of 52,032, which is 8.2% headroom; however, at least 10% is the usual target.
Fig. 9/page 54 shows that 44% of supply in the GCLP is on New Settlements compared to 23% in the current adopted plans. This is a significant shift in strategy that has a higher risk of delay in delivery due to complex sites, the need for major infrastructure where funding is not certain and notoriously long lead-in times. In addition, as noted in paragraphs 2.57-9 and 2,77-81 the issues associated with Water and wastewater infrastructure potentially delaying delivery on big sites in Cambridge. Therefore, it can be argued that a modification should include a higher housing requirement.
Policy S/JH is identified as one of the Local Plan's strategic policies. The whole strategy is based upon balancing jobs and homes across Greater Cambridge. However, substantial employment growth is proposed around Babraham Research Campus, Wellcome Genome Campus, Granta Park and the wider Southern Cluster; whilst the sustainable settlement of Great Abington receives no allocation despite lying immediately adjacent to these employment locations.
This approach is not consistent with NPPF Policy E1, which states:
1. To support business investment and employment, development plans should, at the most appropriate level:
b. Seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment; and
In support of our observations , we include a Socio Economic Benefits Statement prepared by Pegasus in support of a recent appeal at Land north of Pampisford Road, Great Abington. The reports highlights the following important points:
• Extensive evidence exists that the availability and affordability of housing in South Cambridgeshire is a barrier to the growth targeted by the adopted and emerging Local Plans. The range of types and tenures of homes proposed at the site are ideally aligned to the variety of incomes of those working within growth sectors, meaning that they will directly support this growth by alleviating housing pressures. If sufficient housing is not delivered the growth opportunity in areas such as life sciences will be lost to the UK and captured overseas.
• As policy identifies, local services are also critical in support of homes and jobs. A range of local health, education and community service providers are in close proximity to the site. These types of public employers currently struggle with retention and recruitment of staff, with housing typically being the largest single factor. As demonstrated within this report, the mix of market, intermediate and social / affordable rent homes means that a wide range of local keyworkers could afford to live at the site and support the delivery of local public services.
Finally, noting that the Council’s have recently changed the way they are calculating their trajectories, moving from joint to individual supply calculations, our client would suggest that the housing and employment needs for each local authority area should be split up and made clear how they relate to each authority area.
Soundness -
The Plan is inconsistent with Policy S/JH because it plans for significant employment growth in the Southern Cluster but fails to allocate sufficient housing in nearby sustainable settlements capable of supporting that growth in the short to medium term.
In conclusion, Policy S/JH will exacerbate the delays in the delivery of housing and for that reason this policy is not appropriate, as it is not the appropriate strategy taking into account the alternatives; is not positive, as it fails to take proactive steps towards addressing need in the short to medium term; not consistent with national policy and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to Policies HO3 and E1(1)(b) of the NPPF.

Furthermore, and linked to the above our client wishes to make the following comments on Appendices D and E:

Appendix D:
Appendix D relies upon a Greater Cambridge-wide housing trajectory and five-year housing land supply assessment, notwithstanding the authorities' recent decision to calculate housing supply separately on the basis that the HDT results are currently being published separately.
The Greater Cambridge Authorities were previously calculating their supply jointly but, following the publication of the NPPF 2026 and the latest HDT results, they decided that the calculation should be done separately. It is therefore a concern that the joint calculation may fail to demonstrate that housing delivery can be maintained within each constituent authority area, relying upon an evidence base that no longer reflects the authorities' current monitoring and implementation framework.
Separate calculations clearly produce materially different outcomes, where one authority may have a weaker housing supply position than the joint figure suggests, as is currently the case in respect of Cambridge City. This joint trajectory can therefore mask actual delivery risks.
The question my client wishes to raise is whether, given the recent change to the joint calculation that has occurred during the Regulation 19 consultation, an updated calculation will be provided that demonstrates that both authorities will be able to demonstrate a 5 year supply of housing sites at the point of adoption?
My client has limited confidence in the long-term reliability of a joint approach to assessing housing provision, particularly in light of the authorities' repeated changes in position regarding the methodology for calculating housing supply and delivery.
Furthermore, D.4 states that the calculation includes for a 5% buffer base don the anticipated HDT results. This statement is now out of date, and given the recent HDT results require Cambridge City to use a 20% buffer, our client contends that a 20% buffer should be applied to the Cambridge City requirement.

Appendix E:
The proposed Monitoring Framework does not work if the Councils are to split the calculation and make it clear what each authority must provide for during the plan period. Please refer to our objections to policies S/JH and S/DS and Appendix D.