Greater Cambridge Local Plan: Proposed Submission

In order to overcome the issues highlighted in this representation and the enclosed Note on Housing Need and Supply matters and progress a sound Local Plan, it will be necessary to undertake the following additional work and revise the proposed housing requirement accordingly:

• Increase the housing requirement to reflect as a minimum the minimum local housing need of the standard method for 48,090 homes.
• Prepare housing projections which align with the economic ambitions set out in the recently adopted Local Growth Plan, which the CPCA suggest will necessitate a requirement of at least 59,409 homes but potentially substantially more.
• Consider whether it would be sustainable to deliver a greater number of homes to better respond to the acute need for affordable housing.
• In light of the available evidence, this will necessitate a requirement of at least 59,409 homes over the plan period to support the local and national economy, rather than the proposed insufficient housing requirement of 48,069 homes which falls short of meeting even the minimum local housing need and pays no regard to the level of housing necessary to support the local and national economy.

It is requested that the Plan should allocate additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. E W Pepper’s Sites in the villages of Guilden Morden, Steeple Morden, Arrington and Kneesworth are available for allocation and can assist in delivering new housing development in a sustainable way.

E W Pepper objects 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 that 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 Proposed Submission 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 that 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 Proposed Submission 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 comments 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 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 Draft GCLP (Regulation 18) required 2,463 dwellings per annum to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which requires delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period: thus 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 that the GCLP 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 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 housing land supply of the Submission Draft 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 Submission Draft GCLP is exceptional by reference to that which has arisen in other local plans. As such, significant additional work will be required to identify the necessary additional allocations in order for the GCLP to be found sound.

E W Pepper’s Sites in the villages of Guilden Morden, Steeple Morden, Arrington and Kneesworth are available for allocation and can assist in delivering new housing development in a sustainable way.

E W Pepper objects 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 including 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 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 period due to the significant infrastructure required to service the very large allocations. This problem is highlighted in paragraph 2.76 of the Proposed Submission GCLP, 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.

Our view is that the Proposed Submission GCLP 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 GCLP 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 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 Greater Cambridge in the 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 area needs to be identified for development. In allocating the majority of proposed housing at new settlements ignores the desire many may have 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 GCLP 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, including Guilden Morden, Steeple Morden, Arrington and Kneesworth, 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 Proposed Submission GCLP 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 considers that 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.

The indicative maximum scheme sizes for Group and Infill Villages should be deleted.

E W Pepper objects to Draft Policy S/SH.

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

The following Sites should be allocated for housing development under the ‘Rest of the Rural Area’ Chapter of the Plan:

• Land off High Street and Land off Swan Lane, Guilden Morden (HELAA Site ID 40300)
• Land at Town Farm, Guilden Morden (HELAA Site ID 40315)
• Land to the west of Brook End, Steeple Morden (HELAA Site ID 40294)
• Land to the southwest of Ermine Way, Arrington (HELAA Site ID 40292)
• Land to the east of Old North Road, Kneesworth (HELAA Site ID 40299)

The NPPF 2024 (Paragraph 83) states that “Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.” In the same vein, the NPPF 2026 HO6(1b) states that local plans should “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.”

With respect to the ‘Rest of the Rural Area’, the Proposed Submission GCLP is not sound in its approach because it is not positively prepared and does not reflect the approach that national policy requires in respect of supporting and enhancing the vitality of rural areas.

We object to the omission of the following Sites, which should be allocated for development in the ‘Rest of the Rural Area’ Chapter:

• Land off High Street and Land off Swan Lane, Guilden Morden (HELAA Site ID 40300)
• Land at Town Farm, Guilden Morden (HELAA Site ID 40315)
• Land to the west of Brook End, Steeple Morden (HELAA Site ID 40294)
• Land to the southwest of Ermine Way, Arrington (HELAA Site ID 40292)
• Land to the east of Old North Road, Kneesworth (HELAA Site ID 40299)

We request that mandatory wording such as “must” should be replaced with ‘should’. and more flexible language should be incorporated throughout the policy to allow an appropriate balance at decision-making.

We also object to the proposed Important Countryside Frontage affecting HELAA Site ID 40300 at Guilden Morden, which should be deleted on the Policies Map.

We object to Policy GP/LC, which is overly restrictive.

As we stated in our representations to the Draft Plan in January 2026, we object to the use of the word “must” at Policy GP/LC (1). This is too strong given the list of very specific criteria listed: ‘must’ creates a mandatory policy requirement, leaving no discretion for decision makers. The use of the word ‘should’ would be more appropriate, outlining an expectation unless justified otherwise, but allowing for a balanced judgement.

We object to Policy GP/LC(2) which proposes the designation of Important Countryside Frontages (ICF) on the Policies Map. The wording of this element is also considered to be overly prescriptive and restrictive. Other landscape and countryside policies within the GCLP provide adequate protection and proposals should be considered on a site-by-site basis.

Specifically, we object to the identification of ICF on HELAA Site ID 40300 (Land off Church Street in Guilden Morden). This Site does not fulfil the role set out in Policy GP/LC(2) and therefore the application of this designation is unduly onerous. The Landscape justification for our approach is set out in the Vision document for the Site, attached.

Policy GP/LC(3) is also too strong in its language, stating that “Planning permission for development will be refused if it would compromise ICF purposes”. The wording should be more flexible, allowing an appropriate amount of discretion at application stage.

We object to the proposed Important Countryside Frontage affecting HELAA Site ID 40300 at Guilden Morden, which should be deleted on the Policies Map.

We object to Policy GP/LC, which is overly restrictive.

As we stated in our representations to the Draft Plan in January 2026, we object to the use of the word “must” at Policy GP/LC (1). This is too strong given the list of very specific criteria listed: ‘must’ creates a mandatory policy requirement, leaving no discretion for decision makers. The use of the word ‘should’ would be more appropriate, outlining an expectation unless justified otherwise, but allowing for a balanced judgement.

We object to Policy GP/LC(2) which proposes the designation of Important Countryside Frontages (ICF) on the Policies Map. The wording of this element is also considered to be overly prescriptive and restrictive. Other landscape and countryside policies within the GCLP provide adequate protection and proposals should be considered on a site-by-site basis.

Specifically, we object to the identification of ICF on HELAA Site ID 40300 (Land off Church Street in Guilden Morden). This Site does not fulfil the role set out in Policy GP/LC(2) and therefore the application of this designation is unduly onerous. The Landscape justification for our approach is set out in the Vision document for the Site, attached.

Policy GP/LC(3) is also too strong in its language, stating that “Planning permission for development will be refused if it would compromise ICF purposes”. The wording should be more flexible, allowing an appropriate amount of discretion at application stage.

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 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 housing land supply of the Submission Draft 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 Submission Draft GCLP is exceptional by reference to that which has arisen in other local plans. As such, significant additional work will be required to identify the necessary additional allocations in order for the GCLP to be found sound.

E W Pepper’s Sites in the villages of Guilden Morden, Steeple Morden, Arrington and Kneesworth are available for allocation and can assist in delivering new housing development in a sustainable way.

E W Pepper objects 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 including 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 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 period due to the significant infrastructure required to service the very large allocations. This problem is highlighted in paragraph 2.76 of the Proposed Submission GCLP, 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.

Our view is that the Proposed Submission GCLP 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 GCLP 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 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 Greater Cambridge in the 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 area needs to be identified for development. In allocating the majority of proposed housing at new settlements ignores the desire many may have 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 GCLP 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, including Guilden Morden, Steeple Morden, Arrington and Kneesworth, 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 Proposed Submission GCLP 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 considers that 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.

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 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 housing land supply of the Submission Draft 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 Submission Draft GCLP is exceptional by reference to that which has arisen in other local plans. As such, significant additional work will be required to identify the necessary additional allocations in order for the GCLP to be found sound.

E W Pepper’s Sites in the villages of Guilden Morden, Steeple Morden, Arrington and Kneesworth are available for allocation and can assist in delivering new housing development in a sustainable way.

E W Pepper objects 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 including 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 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 period due to the significant infrastructure required to service the very large allocations. This problem is highlighted in paragraph 2.76 of the Proposed Submission GCLP, 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.

Our view is that the Proposed Submission GCLP 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 GCLP 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 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 Greater Cambridge in the 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 area needs to be identified for development. In allocating the majority of proposed housing at new settlements ignores the desire many may have 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 GCLP 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, including Guilden Morden, Steeple Morden, Arrington and Kneesworth, 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 Proposed Submission GCLP 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 considers that 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.

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.

It is requested that the Plan should allocate additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. E W Pepper’s Sites in the villages of Guilden Morden, Steeple Morden, Arrington and Kneesworth are available for allocation and can assist in delivering new housing development in a sustainable way.

E W Pepper objects 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 that 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 Proposed Submission 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 that 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 Proposed Submission 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 comments 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 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 Draft GCLP (Regulation 18) required 2,463 dwellings per annum to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which requires delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period: thus 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 that the GCLP 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.