Greater Cambridge Local Plan: Proposed Submission

The development strategy is reliant upon larger schemes and does not meet the aims of para 83 of the NPPF. As such, additional smaller sites should be added to the Plan, which will assist the Greater Cambridge Authority in their ability to demonstrate a five year housing land supply, particularly in the early years of the Plan.

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

Policy S/DS sets out the main strategic development sites for both residential and employment development through to 2045. This includes carrying over previous sites, whilst also introducing two new large scale housing allocations, with 13,000 homes at Cambourne North and 4,500 homes at Grange Farm proposed (although not all to be delivered in the plan period).

In their Regulation 18 comments in January 2026, Martin Grant Land highlighted sites such as Northstowe, Waterbeach and Bourn Airfield were all allocated within the 2018 Local Plan if not earlier. It remains imperative that strategic sites of this scale are supplemented by a sufficient number of smaller allocations to ensure appropriate delivery in line with housing need.

In January 2026, Martin Grant Land produced a table setting out the difficulties in reliance upon strategic sites and set out the timelines involved in gaining planning permission and completions. This table has been updated below to take into account the information from the Greater Housing Trajectory and Housing Land Supply Report (April 2026):

Site No. of Dwellings Original App Reference Valid Date for Outline Date of Outline Permission No. of Completions at March 25
Bourn Airfield 3,500 S/3440/18/OL 10-9-18 30-7-24 0
Cambourne West 2,350 S/2903/14/OL 22-12-14 29-12-17 765
Darwin Green 1 1,593 07/0003/OUT 19-12-06 18-12-13 542
Eddington 3,000 11/1114/OUT & S/1886/11 22-9-11 22-2-13 1,430
Northstowe Phase 1 1,500 S/0388/12/OL 27-2-12 22-4-14 1,462
Northstowe Phase 2 3,500 S/2011/14/OL 29-8-14 9-1-17 199
Northstowe Phase 3a 4,000 20/02171/OUT 18-5-20 25-3-22 0
Northstowe phase 3b 1,000 20/02142/OUT 7-5-20 25-3-22 0
Waterbeach New Town - West 6,500 S/0559/17/OL 17-2-17 27-9-19 117
Waterbeach New Town - East 4,500 S/2075/18/OL 30-5-18 17-12-24 0

The table shows the difficulty and time required for strategic sites to deliver homes within Greater Cambridge. For example, at Eddington, in the 12 years since the granting of outline planning permission, only 1,430 dwellings have been completed on the site at March 2025. At Bourn Airfield, despite the outline application being submitted in 2018, no reserved matters for residential development have been submitted as of yet. The result of this is that the Greater Cambridge Authority face the danger of not being able to demonstrate a five-year housing land supply through the plan period.

There is an over reliance upon strategic sites in meeting the identified housing need, and this brings an increased risk of delay. It would only take one site to have slow delivery for the five year housing land supply to be affected. The Greater Cambridge Authority should therefore include smaller sites to supplement the strategic allocations and guarantee delivery in the early part of the plan period. Sites such as Silverdale Close, Coton can provide 80 dwellings in a sustainable location to be delivered fully within the first five years of the plan. The site remains suitable, immediately available and achievable.

South Cambridgeshire is a rural district with over 100 villages. Of these, only Melbourn, Duxford and Caldecote stand to benefit from a housing allocation (beyond the strategic sites). Paragraph 2.70 of the draft Local Plan states that villages ‘should play only a limited role in meeting future development needs’. It is suggested that three rural sites within over 100 villages is significantly less than a limited role. The aims and objectives of NPPF (2024) paragraph 83, which states that housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify opportunities for villages to grow and thrive, is clearly not therefore being met to the detriment of the villages. The policy is not therefore considered to be justified when assessed against the tests of paragraph 36 of the 2024 NPPF.

There is also concern regarding the impacts upon 2.80 and 2.81 of the draft plan on delivery. This confirms the need for upgrades to the Cambridge Waste Water Treatment Plant, as well as other waste water treatment works in order to serve the allocations proposed. The Council cannot therefore rely upon strategic allocations where there is a key piece of unresolved infrastructure that may hinder their future delivery. Again, smaller allocations where capacity is less contentious will assist early delivery of sites.

The Plan should include more sites to increase the delivery of affordable housing. There is an acute shortage in South Cambridgeshire

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

The policy sets out the need to provide a minimum of 48,069 dwellings over the plan period, and includes targets for specialist housing such as for older people and students. However, the policy does not set an affordable housing target.

To support planning application 26/01016/OUT, Tetlow King Planning were instructed to undertake an assessment of affordable housing provision within South Cambridgeshire District. The conclusions of this report are as follows:

‘There are serious and persistent affordability challenges across South Cambridgeshire. This is exemplified by the affordability indicators which show a poor and worsening affordability across the South Cambridgeshire.
It is the opinion of Tetlow King Planning that there is an acute housing crisis in South Cambridgeshire, with a lower quartile house price to income ratio of 10.18. Mortgage lending is typically offered based on up to 4.5 times earnings (subject to individual circumstances). Here, the affordability ratio is some 126% higher than that.
Boosting the supply of affordable homes will mean that households needing affordable housing will spend less time in unsuitable accommodation. This will improve the lives of those real households who will benefit from the provision of high quality, affordable homes that meet their needs’

The Affordable Housing Statement is submitted to support these representations, although it should be noted it was drafted to support the planning application. However, it remains relevant given its findings.

The table below has been updated from the figures provided to support the Regulation 18 consultation and sets out affordable housing delivery within both South Cambridgeshire and Cambridge City:

Year. South Cambridgeshire District Affordable Housing Delivery. Cambridge City Affordable Housing Delivery. Total Affordable Housing Delivery.
2024/25 424 263 687
2023/24 503 20 523
2022/23 468 316 784
2021/22 357 147 504
2020/21 303 65 369
2019/20 344 199 543
2018/19 341 345 686
Total 2,740 1,355 4,095

The emerging Local Plan requires an annual total need for 2,289 dwellings. For the seven years described in the table above, affordable delivery averages 585 affordable dwellings per annum. This represents only a quarter of the total housing requirement.

Paragraph 024 (Ref:ID:2a-024-20190220) of the Housing and Economic Assessment section of the Planning Practice Guidance is reiterated. It states:

‘An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes’

Given the identified need and the current level of delivery, there remains clear justification to increase the housing numbers in order to increase affordable housing delivery. This is especially the case within South Cambridgeshire where provision is more consistent. Failure to increase housing numbers would result in increasing affordable housing demands within the authority area. It is suggested that the Plan is not positively prepared and would be unsound as a result.

This leads the Council to be vulnerable to future appeals, especially given the interpretations of policy S5 of the new NPPF in appeal 6005809 (Land to the North of Spring Hill, Kingston Bagpuize with Southmoor, Vale of White Horse District Council). Whilst it is acknowledged that this Local Plan will be assessed against the 2024 NPPF, this appeal decision is relevant for future interpretation and the need for affordable housing to be considered more in the Plan making process.

Policy S5j of the 2026 NPPF states, when considering the principle of development outside settlements, that development to meet unmet need ‘incudes, but not limited to’ five year housing land supply and the Housing Delivery Test. The Inspector concurs that affordable provision would be an unmet need in this instance.

The site at Silverdale Close Coton represents a sustainable location for growth and should be allocated accordingly

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

Planning Application

Martin Grant Land currently has an outline planning application being determined by South Cambridgeshire District Council. The application, reference 26/01016/FUL, was validated on 13 March 2026 for the following development:

‘Outline planning application with all matters reserved other than means of access, for the erection of up to 80 dwellings with associated infrastructure and open space’

Please note the address on the application states Pendrick Close, rather than Silverdale Close. At the time of writing, no constraints on the site have been identified that would preclude the development coming forward. The notes below sets out the responses from statutory consultees to the application.

• Archaeology - Recommend a condition regarding a programme of archaeological works
• Cambridge & Peterborough ICS - Request financial contributions towards healthcare
• Sustainability Officer - Supports general approach being proposed, subject to conditions
• Waste Officer - Seeks further information although this all relates to details that will come forward at reserved matters stage
• Natural England - No objection to the Habitats Regulation Assessment produced.
• Lead Local Flood Officer - No objection subject to planning conditions
• Ecology Officer - No objection subject to planning conditions and regard to potential impact on SSSi’s
• Environment Agency - No objection
• Cambridgeshire County Council - Sets out contributions to be secured through s106 Agreement for SEND provision, libraries and a monitoring fee
• Tree Officer - No objection
• Environmental Health Officer - No objection subject to planning conditions
• Housing Strategy Officer - Sets out the preferred tenure mix
• Local Highway Authority - No objection subject to planning conditions
• NHS Ambulance Service - Request financial contribution
• Anglian Water - Object to connection to the foul water network but sets out condition if application approved.
• Transport Assessment Team - No objection subject to condition and financial contribution towards Greenway works
• Urban Design - No objection
• Landscape Officer - No objection subject to planning conditions
• Health Officer - General support although some queries regarding the Health Impact Assessment content.

As such, no material considerations have been identified that would preclude development on the site. A copy of the parameter plan, as supported by the landscape and urban design officers at the Council, accompanies these representations. It demonstrates an acceptable way for the site to come forward to provide 80 dwellings and ancillary open space.

Housing and Economic Land Availability Assessment (HELAA)

Within the past two representations, concern has been made regarding the assessment of the site within the HELAA. These matters have not been addressed within the 2026 HELAA assessment.

The first matter relates to the rating given for site access. The assessment states that ‘the site does not link to the adopted public highway and is therefore inaccessible to highway users’. This is not the case. The red line has been extended to show connection to the public highway and as previously confirmed, Martin Grant Land has full unencumbered rights of access across Pendrick Close to the site access. As noted above, there are no highway objections to the current planning application at the site. The assessment should therefore change the ‘red’ rating for site access to ‘green’. As such, the suitability of the site would increase accordingly.

Since the Regulation 18 stage, the Cambourne to Cambridge Busway has been approved, with a stop proposed at Cambridge Road in Coton. This further demonstrates the sustainability of the site, given the regular connections proposed into the City and westwards.

The bullets below provide further commentary to the assessment of the site, and is informed by the responses received to the planning application:

• Flood Risk. 2026 HELAA Score: Amber – The application has received no objection from the Local Lead Flood Authority or the Environment Agency.
• Landscape. 2026 HELAA Score: Not shown – It is assumed this will continue the ‘green’ rating as per the 2023 assessment given the lack of material changes to the site.
• Biodiversity. 2026 HELAA Score: Not shown – No objection from Natural England or the Council’s Ecology Officer
• Archaeology. 2026 HELAA Score: Not shown – No objection from the County Council Archaeology Team

The overall suitability score should be reassessed in light of these responses and particularly related to the highways. The overall rating for ‘suitability’ should not therefore be ‘red’.

Grey Belt

In line within the definition of Grey Belt within the NPPF, there is common ground between Martin Grant Land and South Cambridgeshire District Council planning officers, when considering the current application, that the site represents Grey Belt. A Green Belt Assessment by HDA supported the Regulation 18 representations in January 2026 and remains relevant. This assessment has informed the planning application being considered by the Council.

Benefits of the Site

The Regulation 18 representations set out a list of benefits that would result from development at Silverdale Close, Coton. These are again listed below for reference:

• Delivery of up to 80 dwellings
• Provision of 50% affordable housing
• Use of underperforming Green Belt land
• Support existing services and facilities
• Sustainable transport options
• Provision of public open space
• Benefits to Bin Brook
• Off-site highway works
• Other infrastructure contributions

The site remains suitable, immediately available and achievable. It should be considered for allocation as it will allow delivery within the first 5 years of the Local Plan and will complement the large-scale allocations.

The text to Part 1 should make reference to off-site options for BNG, and Part 2 should see a reduction to 10% in line with national policy

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

Part 1

Within part 1 of the draft policy, reference is made that a minimum 10% biodiversity net gain should be achieved and ‘be provided on-site in line with guidance’. With regard to major development, the requirement for on-site net gain includes the caveat of ‘where this is feasible and effective’. It is therefore queried why this caveat is not included within part 1 of the policy too.

It is noted the Planning Practice Guidance (paragraph 001 reference ID:74-001-20240214 Biodiversity Net Gain) states the following:

‘This objective is for development to deliver at least a 10% increase in biodiversity value relative to the pre-development biodiversity value of the onsite habitat. This increase can be achieved through onsite biodiversity gains, registered offsite biodiversity gains or statutory biodiversity credits’

However, this is not reflected within part 1 of the proposed policy which purely states on-site provision only. As such, the policy as written is considered unsound. To rectify, it is therefore suggested that part 1 is reworded as follows:

‘All development must deliver statutory biodiversity net gain (BNG), providing a minimum of 10% BNG against the baseline, unless exempt under the Environment Act 2021, to be provided on-site where this is feasible and effective or off-site where onsite options for BNG have been evidenced to be exhausted as agreed with the relevant Local Planning Authority (LPA)’

Part 2

Part 2 of draft policy BG/BG seeks a 20% biodiversity net gain for major developments. Again, this seems to conflict with the Planning Practice guidance. This states in paragraph 006 reference ID:74-006-20240214 that

‘Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified’

There are serious concerns regarding the impact on viability that would result from a mandatory 20% BNG on major schemes. Given the spatial strategy is fully reliant upon major developments, the risk to delay, reduction of quantum’s and failure of some sites to contribute to delivery is high.

To make the policy sound and consistent with national policy, it is therefore suggested the part 2 of draft policy BG/B is amended to say a 10% requirement.

The site at Silverdale Close Coton represents a sustainable location for growth and should be allocated accordingly

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

Planning Application

Martin Grant Land currently has an outline planning application being determined by South Cambridgeshire District Council. The application, reference 26/01016/FUL, was validated on 13 March 2026 for the following development:

‘Outline planning application with all matters reserved other than means of access, for the erection of up to 80 dwellings with associated infrastructure and open space’

Please note the address on the application states Pendrick Close, rather than Silverdale Close. At the time of writing, no constraints on the site have been identified that would preclude the development coming forward. The notes below sets out the responses from statutory consultees to the application.

• Archaeology - Recommend a condition regarding a programme of archaeological works
• Cambridge & Peterborough ICS - Request financial contributions towards healthcare
• Sustainability Officer - Supports general approach being proposed, subject to conditions
• Waste Officer - Seeks further information although this all relates to details that will come forward at reserved matters stage
• Natural England - No objection to the Habitats Regulation Assessment produced.
• Lead Local Flood Officer - No objection subject to planning conditions
• Ecology Officer - No objection subject to planning conditions and regard to potential impact on SSSi’s
• Environment Agency - No objection
• Cambridgeshire County Council - Sets out contributions to be secured through s106 Agreement for SEND provision, libraries and a monitoring fee
• Tree Officer - No objection
• Environmental Health Officer - No objection subject to planning conditions
• Housing Strategy Officer - Sets out the preferred tenure mix
• Local Highway Authority - No objection subject to planning conditions
• NHS Ambulance Service - Request financial contribution
• Anglian Water - Object to connection to the foul water network but sets out condition if application approved.
• Transport Assessment Team - No objection subject to condition and financial contribution towards Greenway works
• Urban Design - No objection
• Landscape Officer - No objection subject to planning conditions
• Health Officer - General support although some queries regarding the Health Impact Assessment content.

As such, no material considerations have been identified that would preclude development on the site. A copy of the parameter plan, as supported by the landscape and urban design officers at the Council, accompanies these representations. It demonstrates an acceptable way for the site to come forward to provide 80 dwellings and ancillary open space.

Housing and Economic Land Availability Assessment (HELAA)

Within the past two representations, concern has been made regarding the assessment of the site within the HELAA. These matters have not been addressed within the 2026 HELAA assessment.

The first matter relates to the rating given for site access. The assessment states that ‘the site does not link to the adopted public highway and is therefore inaccessible to highway users’. This is not the case. The red line has been extended to show connection to the public highway and as previously confirmed, Martin Grant Land has full unencumbered rights of access across Pendrick Close to the site access. As noted above, there are no highway objections to the current planning application at the site. The assessment should therefore change the ‘red’ rating for site access to ‘green’. As such, the suitability of the site would increase accordingly.

Since the Regulation 18 stage, the Cambourne to Cambridge Busway has been approved, with a stop proposed at Cambridge Road in Coton. This further demonstrates the sustainability of the site, given the regular connections proposed into the City and westwards.

The bullets below provide further commentary to the assessment of the site, and is informed by the responses received to the planning application:

• Flood Risk. 2026 HELAA Score: Amber – The application has received no objection from the Local Lead Flood Authority or the Environment Agency.
• Landscape. 2026 HELAA Score: Not shown – It is assumed this will continue the ‘green’ rating as per the 2023 assessment given the lack of material changes to the site.
• Biodiversity. 2026 HELAA Score: Not shown – No objection from Natural England or the Council’s Ecology Officer
• Archaeology. 2026 HELAA Score: Not shown – No objection from the County Council Archaeology Team

The overall suitability score should be reassessed in light of these responses and particularly related to the highways. The overall rating for ‘suitability’ should not therefore be ‘red’.

Grey Belt

In line within the definition of Grey Belt within the NPPF, there is common ground between Martin Grant Land and South Cambridgeshire District Council planning officers, when considering the current application, that the site represents Grey Belt. A Green Belt Assessment by HDA supported the Regulation 18 representations in January 2026 and remains relevant. This assessment has informed the planning application being considered by the Council.

Benefits of the Site

The Regulation 18 representations set out a list of benefits that would result from development at Silverdale Close, Coton. These are again listed below for reference:

• Delivery of up to 80 dwellings
• Provision of 50% affordable housing
• Use of underperforming Green Belt land
• Support existing services and facilities
• Sustainable transport options
• Provision of public open space
• Benefits to Bin Brook
• Off-site highway works
• Other infrastructure contributions

The site remains suitable, immediately available and achievable. It should be considered for allocation as it will allow delivery within the first 5 years of the Local Plan and will complement the large-scale allocations.

The development strategy is reliant upon larger schemes and does not meet the aims of para 83 of the NPPF. As such, additional smaller sites should be added to the Plan, which will assist the Greater Cambridge Authority in their ability to demonstrate a five year housing land supply, particularly in the early years of the Plan.

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

Policy S/DS sets out the main strategic development sites for both residential and employment development through to 2045. This includes carrying over previous sites, whilst also introducing two new large scale housing allocations, with 13,000 homes at Cambourne North and 4,500 homes at Grange Farm proposed (although not all to be delivered in the plan period).

In their Regulation 18 comments in January 2026, Martin Grant Land highlighted sites such as Northstowe, Waterbeach and Bourn Airfield were all allocated within the 2018 Local Plan if not earlier. It remains imperative that strategic sites of this scale are supplemented by a sufficient number of smaller allocations to ensure appropriate delivery in line with housing need.

In January 2026, Martin Grant Land produced a table setting out the difficulties in reliance upon strategic sites and set out the timelines involved in gaining planning permission and completions. This table has been updated below to take into account the information from the Greater Housing Trajectory and Housing Land Supply Report (April 2026):

Site No. of Dwellings Original App Reference Valid Date for Outline Date of Outline Permission No. of Completions at March 25
Bourn Airfield 3,500 S/3440/18/OL 10-9-18 30-7-24 0
Cambourne West 2,350 S/2903/14/OL 22-12-14 29-12-17 765
Darwin Green 1 1,593 07/0003/OUT 19-12-06 18-12-13 542
Eddington 3,000 11/1114/OUT & S/1886/11 22-9-11 22-2-13 1,430
Northstowe Phase 1 1,500 S/0388/12/OL 27-2-12 22-4-14 1,462
Northstowe Phase 2 3,500 S/2011/14/OL 29-8-14 9-1-17 199
Northstowe Phase 3a 4,000 20/02171/OUT 18-5-20 25-3-22 0
Northstowe phase 3b 1,000 20/02142/OUT 7-5-20 25-3-22 0
Waterbeach New Town - West 6,500 S/0559/17/OL 17-2-17 27-9-19 117
Waterbeach New Town - East 4,500 S/2075/18/OL 30-5-18 17-12-24 0

The table shows the difficulty and time required for strategic sites to deliver homes within Greater Cambridge. For example, at Eddington, in the 12 years since the granting of outline planning permission, only 1,430 dwellings have been completed on the site at March 2025. At Bourn Airfield, despite the outline application being submitted in 2018, no reserved matters for residential development have been submitted as of yet. The result of this is that the Greater Cambridge Authority face the danger of not being able to demonstrate a five-year housing land supply through the plan period.

There is an over reliance upon strategic sites in meeting the identified housing need, and this brings an increased risk of delay. It would only take one site to have slow delivery for the five year housing land supply to be affected. The Greater Cambridge Authority should therefore include smaller sites to supplement the strategic allocations and guarantee delivery in the early part of the plan period. Sites such as Silverdale Close, Coton can provide 80 dwellings in a sustainable location to be delivered fully within the first five years of the plan. The site remains suitable, immediately available and achievable.

South Cambridgeshire is a rural district with over 100 villages. Of these, only Melbourn, Duxford and Caldecote stand to benefit from a housing allocation (beyond the strategic sites). Paragraph 2.70 of the draft Local Plan states that villages ‘should play only a limited role in meeting future development needs’. It is suggested that three rural sites within over 100 villages is significantly less than a limited role. The aims and objectives of NPPF (2024) paragraph 83, which states that housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify opportunities for villages to grow and thrive, is clearly not therefore being met to the detriment of the villages. The policy is not therefore considered to be justified when assessed against the tests of paragraph 36 of the 2024 NPPF.

There is also concern regarding the impacts upon 2.80 and 2.81 of the draft plan on delivery. This confirms the need for upgrades to the Cambridge Waste Water Treatment Plant, as well as other waste water treatment works in order to serve the allocations proposed. The Council cannot therefore rely upon strategic allocations where there is a key piece of unresolved infrastructure that may hinder their future delivery. Again, smaller allocations where capacity is less contentious will assist early delivery of sites.

The Plan should include more sites to increase the delivery of affordable housing. There is an acute shortage in South Cambridgeshire

These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

The policy sets out the need to provide a minimum of 48,069 dwellings over the plan period, and includes targets for specialist housing such as for older people and students. However, the policy does not set an affordable housing target.

To support planning application 26/01016/OUT, Tetlow King Planning were instructed to undertake an assessment of affordable housing provision within South Cambridgeshire District. The conclusions of this report are as follows:

‘There are serious and persistent affordability challenges across South Cambridgeshire. This is exemplified by the affordability indicators which show a poor and worsening affordability across the South Cambridgeshire.
It is the opinion of Tetlow King Planning that there is an acute housing crisis in South Cambridgeshire, with a lower quartile house price to income ratio of 10.18. Mortgage lending is typically offered based on up to 4.5 times earnings (subject to individual circumstances). Here, the affordability ratio is some 126% higher than that.
Boosting the supply of affordable homes will mean that households needing affordable housing will spend less time in unsuitable accommodation. This will improve the lives of those real households who will benefit from the provision of high quality, affordable homes that meet their needs’

The Affordable Housing Statement is submitted to support these representations, although it should be noted it was drafted to support the planning application. However, it remains relevant given its findings.

The table below has been updated from the figures provided to support the Regulation 18 consultation and sets out affordable housing delivery within both South Cambridgeshire and Cambridge City:

Year. South Cambridgeshire District Affordable Housing Delivery. Cambridge City Affordable Housing Delivery. Total Affordable Housing Delivery.
2024/25 424 263 687
2023/24 503 20 523
2022/23 468 316 784
2021/22 357 147 504
2020/21 303 65 369
2019/20 344 199 543
2018/19 341 345 686
Total 2,740 1,355 4,095

The emerging Local Plan requires an annual total need for 2,289 dwellings. For the seven years described in the table above, affordable delivery averages 585 affordable dwellings per annum. This represents only a quarter of the total housing requirement.

Paragraph 024 (Ref:ID:2a-024-20190220) of the Housing and Economic Assessment section of the Planning Practice Guidance is reiterated. It states:

‘An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes’

Given the identified need and the current level of delivery, there remains clear justification to increase the housing numbers in order to increase affordable housing delivery. This is especially the case within South Cambridgeshire where provision is more consistent. Failure to increase housing numbers would result in increasing affordable housing demands within the authority area. It is suggested that the Plan is not positively prepared and would be unsound as a result.

This leads the Council to be vulnerable to future appeals, especially given the interpretations of policy S5 of the new NPPF in appeal 6005809 (Land to the North of Spring Hill, Kingston Bagpuize with Southmoor, Vale of White Horse District Council). Whilst it is acknowledged that this Local Plan will be assessed against the 2024 NPPF, this appeal decision is relevant for future interpretation and the need for affordable housing to be considered more in the Plan making process.

Policy S5j of the 2026 NPPF states, when considering the principle of development outside settlements, that development to meet unmet need ‘incudes, but not limited to’ five year housing land supply and the Housing Delivery Test. The Inspector concurs that affordable provision would be an unmet need in this instance.

Criterion ‘b’ of Part 1 of Policy S/DS should be amended by way of the text highlighted in bold below:
1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge or on the edges of Rural Centres that abut the City;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.

Whilst this local plan is being prepared under the legacy plan making system, with soundness in relation to consistency with national policy being considered against the NPPF of December 2024, the decision-making policies of the NPPF 2026 will nonetheless be material considerations in the determination of any applications for sites not allocated through the Local Plan. This is especially relevant for sites that are physically well-related to existing settlements but outside their development boundaries. These are likely to come forward as speculative applications where there is an evidenced unmet need in accordance with decision-making Policy S5 and GB7. If this unmet need is established, then sites like ‘Land off Ambrose Way, Impington’ (HELAA Site ID 40392 -Site ID 115061), which is being promoted by our client, Martin Grant Land Ltd., are logical locations to deliver sustainable development. Notwithstanding the fact that the site is within the Green Belt, under the decision-making policies of the revised NPPF there is still a policy route to secure planning permission where a housing need is not being met, and the site meets the criteria for being considered as grey belt.

Rather than allowing sites like ‘Land off Ambrose Way’ to come forward unplanned, the
Councils should positively allocate such sites where they would clearly deliver sustainable forms of development. In the case of ‘Land off Ambrose Way’, the site is located on the edge of one of only two Rural Centres that are on the fringes of Cambridge. A Rural Centre that has rapid public transport connectivity with the city (via the Cambridgeshire Guided Busway that connects the city with St Ives) as well as infrastructure that supports walking and cycling connectivity. This would result in new residents being within a twenty-minute walk to the Guided Busway and a twenty-minute cycle to the centre of the city. Accordingly, the ‘Land off Ambrose Way’ site is inevitably more sustainable than sites in the rural southern cluster and at Rural Centres and Minor Rural Centres within the rural area of South Cambridgeshire. The order of preference listed in part 1 of Policy S/DS should be amended to reflect the greater sustainability of sites within and near to the Rural Centres that are on the fringe of Cambridge. Especially, in light of the approach taken by the Government in the revised NPPF, which recognises the benefits of growth through the development of sites physically well-related to existing settlements.

Given the public transport connectivity of Histon and Impington in particular, allocating
sites that are physically well-related to the settlement must form part of the development strategy for the Greater Cambridge area. Especially, as it is inevitable that sites will come forward as speculative applications when an unmet need for housing can be evidenced. What constitutes ‘unmet need’ is likely to be determined by legal cases. Indeed, the text of Policy S5(j) confirms that it is not limited to development proposals involving the provision of housing where the local planning authority cannot demonstrate a five year supply of deliverable housing sites or scores below 75% in the most recent Housing Delivery Test. This indicates that there are other unmet needs that could trigger Policy S5(j), such as an unmet need for affordable housing on the edge of one of the least affordable cities in the country.

The allocations in the emerging Local Plan do not recognise the role that sites of 100 dwellings or less, like the ‘Land off Ambrose Way’ site, can play in delivering a more diverse growth strategy through a greater range of sites in sustainable locations where levels of car use for travel to work would not necessarily be higher than in the Rural Centres and Minor Rural Centres within the wider rural area. Allocating more sites on the edges of Rural Centres on the edge of Cambridge would be a positive response to the challenges of net zero carbon and Climate Act obligations and not undermine the Councils’ vision and strategic priorities.

National planning policy states that plans should set out “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”. The 2026 revisions of the NPPF now mean that growth utilising sites that are physically well-related to Rural Centres is a reasonable alternative that needs to be considered. If not, then it risks undermining the emerging Local Plan through speculative applications supported by Policy S5(j) resulting in unplanned growth.

Figure 9(1) shows how the development strategy is focussed on larger sites including new settlements. Indeed, 81% of the homes to be delivered across Greater Cambridge are on sites of 1,000 or more homes. These can take years to deliver new homes as has been evidenced by sites like Eddington and Cambridge East. The allocation of a greater range of sites would offer greater resilience to changes in the housing market and increases in materials and energy costs that may slow the build out of larger strategic sites. There would also be the added benefit of ensuring a more robust five-year supply position in the early years of the plan. As well as the delivery of more affordable housing nearer to the city.

The benefits of delivering housing near to public transport infrastructure (the Guided Busway that provides connectivity with all three Cambridge stations) that provides access to London has wider, regional benefits in meeting some of the housing needs of the capital. The recently published draft London Plan indicates that there would be a significant undersupply of housing in the first ten years after its adoption. The draft London Plan’s approach to increasing housing supply towards the end of the plan period will inevitably have an impact upon settlements outside of London that have traditionally been used by commuters reliant on the railway. This potential wider housing need for the southeast of England is likely to put further pressure for development in the Greater Cambridge area.

The emerging Local Plan proposes to allocate more employment sites within and near to
Vision Park, Histon. These are in addition to new employment opportunities that will be created by the densification of both the Cambridge Science Park and Cambridge Business Park. These sites are on the route of the Guided Busway and within cycling distance of the ‘Land off Ambrose Way’ site. Delivering more new homes near to these large employment sites would meet the requirements of paragraph 111 of NPPF by seeking to minimise the length and journeys needed for employment opportunities.

Given the Councils’ reliance on windfall sites for part of their development needs, the
revisions to the NPPF and the impact they will have on delivery of housing on sites
physically well
-related to existing settlements where an unmet need can be evidenced must now be acknowledged. The Councils’ evidence for its windfall allowance is based on in-depth analysis of historic housing completions on windfall sites and consideration of future trends taking account of national legislation, and national and local planning policy. Given the timing of this consultation, it is inevitable that this in-depth analysis could not have taken into account the recent revisions of the NPPF and the implications of applications coming forward in compliance with Policies S5 and GB7 in particular. Accordingly, the development strategy must consider the implications of Policies S5 and GB7 on the determination of applications for unallocated sites and use this as an opportunity to allocate more sites of 100 dwellings or less that are physically well-related to existing settlements, especially those high order settlements on the fringes of Cambridge.

The Government is clear that sustainable development in line with Policy S3 of the 2026 NPPF can be delivered by the development of sites within that are physically well-related to existing settlements. Sites such as ‘Land off Ambrose Way’ have effectively been given a green light for applications to be supported where they comply with Policy GB7(1)(G) and S5(j). However, there is still a risk for developers in attempting to secure planning permission for such sites. This risk could be removed by the emerging Local Plan allocating them for development.

Given the clear sustainability of Rural Centres on the edge of Cambridge the development potential of land physically well related to them cannot be ignored as they now offer a reasonable alternative for meeting some of the growth needs of Greater Cambridge. In light of the 2026 NPPF changes, Policy S/DS should recognise how sites like ‘Land off Ambrose Way’ can deliver more sustainable development than sites in rural areas.

Footnotes:
1 Figure 9: Distribution of growth in comparison to previous Local Plans

Under the Rest of rural area, a specific allocation is included for:

Up to 100 dwellings on ‘Land off Ambrose Way, Histon’ (HELAA Site ID 40392 -Site ID 115061).

Figure 9(1) shows how the development strategy is increasingly focussing larger sites including new settlements. Whilst these have an important role in housing delivery, they can take years to deliver new homes and employment opportunities. Indeed, 81% of the homes to be delivered across Greater Cambridge are on sites of 1,000 or more homes. Therefore, the development strategy could be made more robust by offering more opportunities for developers of sites of 100 dwellings or less that are more likely to be built out faster if they are allocated through the emerging Local Plan. This approach would offer greater resilience to changes in the housing market and increases in materials and energy costs that may slow the build out of larger strategic sites. There would also be the added benefit of ensuring a more robust five-year supply position in the early years of the plan until such time as the larger sites start to deliver new homes.

Requiring developers of sites of 100 dwellings or less to have a greater reliance on unallocated sites means that applications for such sites have greater risks of not being approved if they are outside settlements. As the principle of their development is not established through an allocation even when they are in sustainable locations. This means that developers inevitably have to look for less certain sites where the costs of attempting to secure a planning consent, and the risks of not achieving one would inevitably be higher.

Our client, Martin Grant Land Ltd., is promoting their site at ‘Land off Ambrose Way, Histon’ (HELAA Site ID 40392 -Site ID 115061). This site is physically well-related to the Rural Centre of Histon and Impington and could deliver up to 100 dwellings near to employment opportunities and the Guided Busway. This offers a more sustainable form of development than other sites that are proposed to be allocated through the emerging Local Plan. Through previous call for sites Martin Grant Land Ltd. has demonstrated that the site is deliverable and any impacts of its development could be mitigated.

The Councils recognise that to help Greater Cambridge transition to net zero carbon by 2050 it is essential that development is sited in places that help to reduce carbon emissions. Accordingly, the development strategy seeks in part to maximise opportunities for growth by the location of existing and committed public transport schemes. Examples of this are development north of Cambourne taking advantage of the proposed East West Rail station and Cambridge East being supported by the proposed Cambridge Eastern Access public transport corridor improvements. Weight is also attached to the potential for a new rail station to be delivered on the site to make it more sustainable.

It is clear from this strategy that significant weight is being attached to delivering growth around future public transport routes. This broadly accords with the approach taken by the Government in the 2026 revisions of the NPPF, which seek to focus growth around existing, well-connected stations. Specifically, compliance with decision-making Policy S5(h) meaning that applications for sites near to well-connected stations should be approved, unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in the NPPF. Whilst ‘Land off Ambrose Way’ is not near a well-connected station, it is near to the Guided Busway, which provides rapid public transport connectivity with Cambridge and all three of its railway stations.

Whilst this local plan is being prepared under the legacy plan making system, with soundness in relation to consistency with national policy being considered against the NPPF of December 2024, the decision-making policies of the NPPF 2026 will nonetheless be material considerations in the determination of all applications, including those for unallocated sites. This is important as the Councils recognise that windfall sites are a valuable supply of new homes and employment opportunities. However, the emerging Local Plan is failing to capitalise on the benefits of windfalls sites that are now likely to come forward on sites that are physically well-related to existing settlements where an unmet need can be evidenced in accordance with Policy GB7(1)(G) and S5. This is a missed opportunity to strengthen the supply of new homes and mixed-use developments whilst also providing greater opportunities for developers of sites of 100 dwellings or less. Therefore, the emerging GCLP needs to acknowledge the potential for more sites to deliver new homes as part of a plan led process, rather than through allowing them to come forward as windfalls on unallocated sites.

The allocation of sites of 100 dwellings or less, like ‘Land off Ambrose Way’, on the edge of a Rural Centre that is on the edge of Cambridge would not compromise the development strategy. Rather, it would offer an opportunity to deliver a more diverse growth strategy through a greater range of sites in sustainable locations where levels of car use for travel to work would not necessarily be higher than in Rural Centres and Minor Rural Centres that are within the rural area. This change would be a positive response to the challenges of net zero carbon and Climate Act obligations and not undermine the Councils’ vision and strategic priorities.

National planning policy states that plans should set out “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”. The 2026 revisions of the NPPF now mean that growth focused around sites that are physically well-related to existing settlements is a reasonable alternative that needs to be considered. If not, then it risks undermining the emerging Local Plan through speculative applications supported by Policies S5(j) and GB7(1)(G) resulting in unplanned growth.

The Councils’ evidence for its windfall allowance is based on in-depth analysis of historic housing completions on windfall sites and consideration of future trends taking account of national legislation, and national and local planning policy. Given the timing of this consultation, it is inevitable that this in-depth analysis could not have taken into account the recent revisions of the NPPF and the implications of applications coming forward in compliance with Policies S5 and GB7 in particular. Accordingly, the development strategy must consider the implications of Policies S5 and GB7 on the determination of applications for unallocated sites and use this as an opportunity to allocate more sites of 100 dwellings or less that are physically well-related to existing settlements. Especially, the Rural Centres that are physically well-related to Cambridge.