Greater Cambridge Local Plan: Proposed Submission

The Policy needs to include more flexibility in relation to the required housing mix to reflect the circumstances of each site and its context as well as market demand and evidence of local needs in accordance with Government policy.

Endurance Estates objects to Policy H/HM since the proposed requirements of the Policy are considered to be unduly onerous and are not justified, positively prepared or consistent with National Policy.

This policy sets out the mix of housing to be provided by new development, to ensure that new homes are generally of a size and type that meet the housing needs of different groups in the community.

However, Endurance consider that the Policy is unduly restrictive and should include more flexibility in relation to the required housing mix to reflect the circumstances of each site and its context as well as market demand and evidence of local needs in accordance with Government policy.

The Policy Map should be amended to include the identification of the Site at Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)as an allocation for new housing development.

Endurance Estates strongly objects to the proposed inset map for Orwell on the basis of the omission of a site-specific policy allocating Land at Hillside, Orwell, Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496) for residential development. For the reasons outlined in our response to Policy S/RRA, the Policies Map for Orwell is considered to be not positively prepared or justified and is therefore unsound.

As a Group Village, Endurance Estates contend that a development such as Land at Hillside could contribute towards meeting the market and affordable housing needs of the Village through the development of approximately 25 new homes.

The Policies Map should therefore be updated to allocate Land at Hillside, Orwell, for a residential development of approximately 25 new homes.

To require Biodiversity Net Gain to achieve the National and Legislative requirements only.

Endurance Estates objects to Policy BG/BG since the proposed requirements of the Policy are considered to be unduly onerous and are not justified, positively prepared or consistent with National Policy.

The requirement to achieve Biodiversity Net Gain of 20%+ set out within the Policy goes beyond National Policy and Legislative requirements. Paragraph N1.2 of the National Planning Policy Framework (published 17 August 2026) states: “Development plans should only set local standards for biodiversity net gain which are in excess of the statutory net gain requirement where this is for specific site allocations, and is fully justified and deliverable.”

Whilst the Greater Cambridge Local Plan is to be assessed having regard to the National Planning Policy Framework (published December 2024), it is important to have regard to Annex A of the August 2026 NPPF which states that “development plan policies (or parts of those policies) which are materially inconsistent with national decision-making policies in this Framework should be given very limited weight”. As a result, planning applications in Greater Cambridge will now only be required to meet the 10% minimum BNG requirement set out in national regulations.

Endurance is concerned that the proposed policy requirement goes beyond Government policy and legislative requirements, contrary to National Policy and has not been demonstrated to be justified, viable or deliverable. It is considered that the emphasis of the policy should be on achieving the National and Legislative requirements whilst encouraging an increase beyond this where possible to ensure that the proposed policy is sound.

The Policy Map should be amended to include the allocation of the Site at Land East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250) for a residential-led development to include the provision of approximately 1,500 new homes, employment development, neighbourhood centre and supporting uses along with a new country park.

Endurance Estates object to the draft Policy S/EOC as it is considered that the Policy is unsound on the basis that it is not positively prepared, justified or effective when considered against the reasonable alternatives and evidence available.

Draft Policy S/DS states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and is considered to be broadly logical and justified.

However, despite the Edge of Cambridge being identified in the Settlement Hierarchy / Development Strategy as being the second most sustainable location for directing new housing and employment growth, the Councils have not identified any further sites on the edge of Cambridge in order help meet the areas needs.

As highlighted in our representations to Policies S/DS and S/GB, it is considered that the Development Strategy should be supplemented by the provision of additional allocations on the Edge of Cambridge, with land removed from the Green Belt, to create a more balanced housing land supply which mitigates the risk of delayed delivery from the New Settlements and enables a more balanced and sustainable pattern of growth which better supports the needs of the Greater Cambridge economy, as evidenced in the Greater Cambridge Economic Needs Assessment which supports these representations. This would meet a wider range of housing needs (including affordable housing needs) across the whole area whilst also addressing the inadequate housing supply buffer previously referred to.
The concentration of further growth on the edge of Cambridge would result in development being located in the next most sustainable location after the urban area (as acknowledged in the Plan) where development for new housing can come forward quickly, benefiting from the existing infrastructure and proximity to jobs, services and facilities. This is recognised by the Sustainability Appraisal as some of the most sustainable locations for growth in terms of access to services, facilities and healthcare, equal to options of densification of the city and new settlements.
By allocating new housing development on the edge of the City and close to existing and planned employment growth, the Development Strategy would both better meet and address Cambridge’s unmet need for market and affordable housing and would better support the growth of the economy given the ability for new residents to access jobs at the various business parks on the fringes of the City and within the City Centre by active travel and other sustainable modes.
In terms of Green Belt, the Council’s Development Strategy Topic Paper Appendix 4 (Cambridge Local Plan Green Belt Considerations) 2026, identifies that Land East of Gazelle Way (40250) partially comprises Grey Belt, by virtue of overlapping with Grey Belt Parcel TE9, which is a 2.29 hectare parcel on the edge of Teversham.

It is acknowledged that the ‘Review following changes to National Policy and Guidance’ document, prepared by LUC in July 2026, does not identify any of the other parcels comprising the promotion site (CHI1, CHI2, CHI3, CHI4, TE7 and TE8 and FU1) are identified as provisional green belt, and each is identified as having a ‘very high’ harm rating, with the exception of CHI3 which is given a ‘high’ harm rating. The Assessment concludes that the site has a ‘strong’ contribution to NPPF Purpose D. None of these assessments have changed since the LUC August 2021 Greater Cambridge Green Belt Assessment and Endurance disputes their findings and considers that the evidence has been prepared retrospectively to justify a strategy already determined rather than providing a fully objective assessment.

The constraint of the Green Belt is understood and acknowledged. However, the Green Belt evidence relied upon by the Council makes no attempt to identify Green Belt land which would represent some of the most highly sustainable locations for growth anywhere in the Greater Cambridge region. Paragraph 2.51 of the Proposed Submission which follows Policy S/DS states that “We made sure to consider the sustainability impacts of focusing growth outside the green belt in comparison with alternatives of releasing green belt land, as we are required to do by national planning policy”. Paragraph 2.50 then states that the Councils “also identified six development strategy choices which form geographically focused hybrids of the previously identified sources of supply” which included “A hybrid involving release of land from the Green Belt.” The Councils have not given sufficient weight to the climate crisis and housing crisis we now face (which were not material factors when the green belt policy was originally established), and these are exceptional circumstances which would justify a more flexible and permissive approach to the release of green belt and grey belt land.

The updates made to the Assessment are light-touch, and essentially boil down to corrections and updates, such as the amendments made in the Assessment for sites which have seen recent development, including for example Land South of Trumpington. Regrettably, the Council have not applied the same update to Land East of Gazelle Way, Cherry Hinton, which is now similarly influenced by recent developments at the Land North of Cherry Hinton site, which continues to be built out at pace. The site is now effectively surrounded on all sides by built form: Cherry Hinton to the west; Capital Park to the south; Teversham to the north-east and Fulbourn to the south-east. Planned development, including supporting facilities for East West Rail to the south-east of the site will also continue to evolve the surroundings over the next Plan period.

Endurance Estates have undertaken significant technical work in support of their promotion of Land East of Gazelle Way, Cherry Hinton in order to demonstrate that the proposed scheme can come forward in accordance with the revised Green Belt policies set out in the 2026 NPPF.

Despite the significant housing needs identified within Greater Cambridge and the lack of available brownfield sites within Cambridge to meet their own needs, the Plan makes only a single new allocation within the Green Belt at Cambridge Biomedical Campus. It is therefore considered that the Council should urgently undertake a full Green Belt Review in accordance with the NPPF and PPG to identify potential Grey Belt of other suitable sites on the edge of Cambridge which can sustainably contribute Greater Cambridge’s demonstrable housing and employment needs.
East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250)
Endurance Estates strongly objects to the omission of the proposed allocation site at Land East of Gazelle Way.
Endurance Estates has consistently promoted Land East of Gazelle Way for a mixed-use, landscape-led development of approximately 1,250 dwellings, employment space and extensive public open space. The site comprises 120 acres on the edge of Cambridge which is currently in agricultural use.
Land East of Gazelle Way is an unparalleled location for growth and can readily connect to the existing and committed infrastructure of Cambridge without the need for substantial additional costly infrastructure.
Land East of Gazelle Way is well located for access to key existing employment sites, including Capital Park (Cam Life) and Fulbourn Hospital, which sit immediately south of the railway line, and Peterhouse Technology Park, which lies to the southwest and can be reached within a six-minute cycle. These employment sites represent a growing cluster, which benefit from significant investments, including from occupiers such as ARM, which has its global HQ on the Peterhouse Technology Park and is expanding significantly.
In recognition of its highly accessible location, the east of Cambridge area is expected to become a focus of employment and infrastructure growth over the coming decade. As part of this, projects including the Cherry Hinton Innovation District development at Coldham’s Lane (circa 1.5km west of the site) and the Cambridge East development at Cambridge Airport (circa 1.6km north-west), will both come forward and transform this part of the City.
Significant infrastructure is already committed to accommodate this growth, including the Fulbourn Greenway, EWR’s proposed Cambridge East Station and the relocation of the Newmarket Road Travel Hub to Teversham, complementing the existing high quality public transport and cycle connectivity within this area.
To compliment this further, the proposed East of Gazelle Way scheme, would deliver new high-quality off-road cycle route connecting with the Fulbourn Greenway to the south and up to the Cambridge East to the north.
Attached to these representations is an extract from the 2025 HELAA site assessments, accompanied by comments from the Endurance Estates’ project team. This demonstrates that, based on the updated technical information available, the Site would score green against most criteria with amber in relation to the remaining criteria and no red scores.
In addition to the HELAA assessment, it is important to consider whether the site qualifies as Grey Belt land. According to the latest PPG, land which does not contribute strongly to Green Belt Purposes (a), (b) or (d), can be considered to comprise Grey Belt. Below is a brief assessment of Land East of Gazelle Way which demonstrates that the Site can be considered Grey Belt.
In terms of Purpose A (to check the unrestricted sprawl), while it is accepted that the proposed site would encroach into the countryside, it is our view that the site performs weakly against Purpose A. The site is largely enclosed by Cherry Hinton to the west, Springstead Village to the north, the former Ida Darwin Hospital development to the south-east and Capital Park/CamLife Campus which sits the south. The southern boundary is comprised of the Cambridge to Newmarket railway line. There are also other existing urban influences to the south in the form of the National Grid/UKPN Grid Substation, and a mobile home park with the Yarrow Road Tesco beyond. The site is therefore considered to be well contained and would be a logical extension to Cambridge. Once developed, the site would represent a logical limit to Cambridge, whilst preserving a landscaped buffer between the scheme, Teversham and Fulbourn providing separation and protecting their individual identity. This buffer would be similar in scale to that provided between Darwin Green and Girton.
In conclusion, it is considered that the site makes a moderate contribution to Purpose A and does not therefore contribute strongly to this purpose.
In terms of Purpose B (Prevent neighbouring towns merging into one another) the revised PPG confirms that this relates solely to the merging of towns, and not villages. Given the nearest town to the east of the site is Newmarket, approximately 10km away it is considered that the site makes no meaningful contribution to fulfilling this purpose.
Nevertheless, the proposals submitted include a substantial open landscape buffer which would preserve the setting of both Teversham and Fulbourn maintaining separation and preserving their individual identity. Once provided, the landscaped buffer would retain a visual separation between the proposals and both villages, which could be incorporated into open space, biodiversity enhancement areas or a country park – subject to further technical work and discussions with Greater Cambridge. This would effectively secure this buffer in perpetuity, rounding off development to the East of Cambridge.
In conclusion, the Site makes only a weak/no contribution to Green Belt Purpose B and does not therefore contribute strongly to Purpose B.
For Purpose D (to preserve the setting and special character of historic towns), again, the revised PPG confirms that this relates solely to towns (and not villages). Accordingly, the only historic town relevant to the site is Cambridge. The last Green Belt Assessment (LDA, August 2021) published by the Council confirmed the promotion site contributed only moderately to purpose 2 (maintaining and enhancing the quality of Cambridge’s setting), reflecting the presence of relatively modern developments in and around Cherry Hinton, which do not contribute to the historic character or setting of the City.

In conclusion, the Site only makes a weak to moderate contribution to this purpose and does not therefore contribute strongly to Purpose D.
Further, in terms of the Golden Rules for Green Belt Release, the site is fully capable of meeting the requirements as outlined in Policy GB8 of the NPPF 2026.

Initial technical investigations on the indicative design confirm that Land East of Gazelle Way can viably deliver 50% affordable housing, which would significantly help meet the pressing need for affordable housing in the City.

Alongside this, the proposed scheme is capable of contributing towards necessary infrastructure, including provision of a new primary school and contributions to required sustainable transport infrastructure. The site design is capable of incorporating safe active travel routes throughout, and the Site will be easily accessible and will provide enhanced linkages to the Fulbourn Greenway, relocated Teversham Travel Hub and the potential future Cambridge East Station at Coldham’s Lane. Endurance Estates would welcome discussions with Greater Cambridge relating to required infrastructure contributions.

The proposed scheme will also include substantial public open space, providing enhanced public access to the countryside, linking with existing Public Rights of Way for existing and future residents. This will build-on the Cambridge Nature Network and the proposals at the nearby Springstead Village and Cambridge East Sites. The site is therefore capable of meeting the NPPF’s Golden Rules for Green Belt release. The Scheme is capable of providing connectivity through to the planned green infrastructure at the Cambridge East development, helping provide additional connectivity in line with the ambitions of the Cambridge Nature Network Local Nature Recovery Strategy, providing greater benefit to nature and contributing to the delivery of wider environmental outcomes.

As such, it is concluded that the site is likely to constitute Grey Belt and is capable of complying with the Golden Rules of Green Belt release outlined in Policy GB8 of the NPPF 2026. As stated in Policy GB8(2) of the NPPF 2026), development which complies with the Golden Rules should be given significant weight in favour of granting permission.

Endurance Estates contends that, subject to ongoing technical investigations, Land East of Gazelle Way is capable of contributing to the identified housing needs of Greater Cambridge. The site is Available for development within the first 5 years of the Local Plan Period and remains Achievable and Suitable for the development proposed.

Endurance Estates requests that Greater Cambridge urgently publish the updated Green Belt Assessment and remove Land East of Gazelle Way from the Green Belt, with a corresponding allocation for residential-led mixed-use development of the site.

Conclusion

Accordingly, the lack of any new housing allocations on the Edge of Cambridge identified within the Proposed Submission Local Plan despite the high levels of unmet market and affordable housing within the City and it representing the next most sustainable location in the Settlement Hierarchy for new development is considered to be unjustified and unsound. In particular, Endurance Estates objects to the omission of Land East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250) as a new residential-led allocation and considers this to be unsound.

Endurance Estates object to the draft Policy S/EOC as it is considered that the Policy is unsound on the basis that it is not positively prepared, justified or effective when considered against the reasonable alternatives and evidence available.

To ensure that Appendix C and the Plan more widely is sound, Endurance Estates contend that the Local Plan should be amended to:
 Increase the proportion of growth directed to neighbourhood areas.
 Update the mechanism for distributing the residual housing needs to ensure that it is robust and consistent across the Plan policies.
 Ensure that market and affordable housing needs in each of the neighbourhood areas are addressed in full.
 Clarify the relationship between the Appendix C housing requirements and Neighbourhood Plans.
 Confirm that these housing requirements are intended as minimum figures and not as a ceiling to village growth.

Appendix C – Housing Need in Neighbourhood Areas.

Endurance Estates object strongly to the housing figures for Neighbourhood Areas set out in Appendix C on the basis that the methodology remains overly simplistic and is not positively prepared, justified or effective. Consequently, Appendix C is considered to be unsound.

There has been no fundamental change to the calculation of housing need in neighbourhood areas in the Regulation 19 version of the plan. Accordingly, it remains unclear what relationship, if any, the figures provided in Figure C1 bear to identified local market and affordable housing needs. At present, it appears that the apportionment is a simple proportional basis, based upon the current population, which is then divided by the residual identified need of 6,183 dwellings which are to be delivered “from other sources or through windfall sites”.

A simple apportionment approach is considered too simplistic and should be updated to reflect the true level of unmet local affordable, market and specialist housing needs. Local needs are influenced by local characteristics, demographics, affordability, and should consider any spare capacity in existing local services, alongside projected demographic trends.

Moreover, the current method does not appear to reflect the settlement hierarchy and takes no account of existing service provision or capacity. As a result, smaller villages which nonetheless have a good level of service provision are apportioned a smaller number of homes than larger villages which have a relatively poorer level of public services.

Endurance Estates representations to Policy S/JH and Policy S/DS raise significant concerns with regard to the housing requirement and the proposed Development Strategy and contend that the Local Plan should include a higher housing requirement to provide a better balance between homes and jobs and that more housing should be directed to sustainable villages to help meet local needs. It therefore follows that such changes would also require the level of housing needs directed to neighbourhood areas to be increased.

For these reasons Endurance Estates contend that the Councils should seek to both increase the proportion of growth directed to neighbourhood areas and to update the mechanism for distributing the residual housing needs to ensure that it is robust and consistent across the Plan policies. Appendix C and the Local Plan as a whole should be amended to ensure that market and affordable housing needs in each of the neighbourhood areas are addressed in full.

The relationship between the Appendix C housing requirements and Neighbourhood Plans should also be clarified. At present, it is not clear whether the needs identified are to be delivered through forthcoming Neighbourhood Plans or whether these are in addition to any needs identified through the Neighbourhood Plan-making process. It is also not clear whether these figures should take precedence to any identified figures in Neighbourhood Plans and whether this would include or exclude windfall development. Endurance Estates contend that this position is unacceptably subjective and open to significant interpretation from decision makers and should be addressed through amendments to the Plan.

Clarification should also confirm that these housing requirements are intended as minimum figures and not as a ceiling to village growth.

Endurance Estates therefore consider that the housing figures set out in Appendix C is not positively prepared, justified or effective and the Policy is therefore considered to be unsound.

The Development Strategy to provide for an increased level of housing provision of a minimum of 56,000 new homes over the Plan period (2,667 dwellings per a annum) in accordance with the higher levels of housing growth considered within the Sustainability Appraisal and with a minimum 10% buffer to more fully support the local economy, supporting planned jobs growth and helping to address the historic imbalance between homes and jobs to address commuting patterns.

Moreover, based on our supporting evidence within the Greater Cambridge Economic Needs Assessment, the Plan should seek to aim for an aspirational housing supply target of 66,000 new homes to help address the imbalance between homes and jobs and fully support the Greater Cambridge economy.

In addition, given the reliance on New Settlements, a larger housing supply buffer should also be provided of a minimum of 10% in order to ensure that the Councils are able to maintain a five-year supply od deliverable sites throughout the Plan period including on Adoption of the Plan. This should include more medium and small sized sites in order to help provide a more flexible, robust and deliverable supply in accordance with the intentions of the NPPF.

Accordingly, additional sites should be allocated in the form of new urban extensions on the edge of Cambridge such as Endurance Estates site at Land East of Gazelle Way, Cherry Hinton along with additional small and medium sized housing sites in sustainable villages in the Rural Area including Endurances sites:
 Land East of Gazelle Way, Cherry Hinton (Site ID 115222; HELAA ID 40250).
 Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
 Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)
 Land off the Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
 Land off Elbourn Way, Bassingbourn (Site ID 116006, HELAA ID 40227)
 Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)

Appendix D - Housing Trajectory & 5YHLS.

Endurance Estates strongly objects to the Housing Trajectory at Appendix D and considers that it is unsound on the basis that the housing trajectory includes insufficient sites with too much reliance placed on delivery at New Settlements. Moreover, notwithstanding Cambridge’s recent Greater Cambridge Housing Trajectory and Housing Land Supply Report - Addendum (September 2026), Endurance consider that the Councils are currently unable to demonstrate a 5-year housing land supply. As a result, it is considered to that the Housing Trajectory at Appendix D is not positively prepared, justified, effective or consistent with national policy and is unsound.

Overall Housing Supply

The Regulation 19 Plan outlines how the Council intends to deliver a minimum of 48,195 new homes between 2024 and 2045. After reviewing the delivery assumptions in Figure D1 (‘Anticipated Completions 2024 - 2025’) of the Proposed Submission Plan, Endurance Estates considers the projected delivery rates to be unrealistic.

A strategy that includes a particular focus, and reliance, on strategic sites in Greater Cambridge is logical and supported in principle. However, it does though lead to the conclusion that Greater Cambridge needs to adopt a more substantial housing supply buffer than the contended 8.2% currently proposed. A higher buffer would provide the necessary flexibility of delivery and ensure a robustness of supply in accordance with the intentions of the NPPF.

The current buffer is insufficient and fails to recognise the delivery challenges which have historically held back early delivery on the large-scale strategic sites within Greater Cambridge. As a result, Greater Cambridge should employ a housing land supply buffer certainly over 10% and we would suggest circa 15-20% above the identified requirement which, for the reasons set out under the Policy S/JH: New Jobs and Homes heading above, also needs to be higher than the Standard Methodology figure.

Endurance Estates therefore consider that the 8.2% housing supply buffer currently proposed on the housing requirement for the Plan period, upon which the allocations and trajectory are based, is insufficient and will put the delivery of the housing requirement at risk, stifling economic growth. In addition, it is considered that it will result in Greater Cambridge being unable to demonstrate a five-year supply of housing land either upon or shortly after adoption and a risk to the delivery of the Plan’s overall housing requirement as discussed further below.

5-Year Housing Land Supply

The Greater Cambridge Shared Planning Service Housing Delivery Study Addendum 2026 Update includes a Trajectory for the Proposed Submission Local Plan as its Appendix A.1 with Five year housing land supply calculations at A.2. This assumes the Local Plan is adopted in the 2028/29 monitoring year, and the first five-year housing land supply calculation period is 1st April 2028 to 30th April 2033. Even by the Councils’ own calculations, the land supply would only be 5.03 years (Sedgefield method) / 5.47 (Liverpool method) and remains below 6 years until 2034/35 (Sedgefield method) / 2035/36 (Liverpool method).

It should also be noted that the calculation of the 5YHLS in Appendix 1 (on a joint basis) is different to the approach the Councils are now seeking to take for current decision-making purposes with the Councils now calculating the 5YHLS on a joint basis. The two approaches are inconsistent and will lead to uncertainty. In this regard, Endurance consider that the 5YHLS position should be calculated jointly and therefore agree with the approach within the emerging Plan in this regard.

We would also emphasise that the PPG [Paragraph 68-031] is clear that the Sedgefield method should be utilised for calculating the 5-year housing land supply position unless justified otherwise. The Council has provided no clear justification as to why the Liverpool method should be used for calculating the housing land supply position and accordingly the Sedgefield method should be used in accordance with National policy. On this basis, the Council’s 5-year housing land supply would be extremely marginal and at risk from any delays in major sites coming forward.

It is therefore evident that the land supply is fragile even by the Councils’ own calculations, and any delay to the delivery of the newly allocated sites, or the pace of delivery on the previous allocations, could mean the Council falling below the required 5 years. Additional identified supply through small and medium sized sites coming forward in the first five years post adoption would provide the necessary contingency to ensure the five-year supply is maintained, and the plan remain up to date.

Notwithstanding the Councils’ recent 5YHLS addendum, Savills consider that the Councils are currently unable to demonstrate a five-year housing land supply. The projected shortfall is primarily due to unrealistic delivery assumptions at several key strategic sites. These include Northstowe, Waterbeach, and Bourn Airfield, and extend to other large allocations that lack clear evidence of delivery commencing within the five-year period.

To ensure that Greater Cambridge’s five-year housing land supply upon adoption is secure, the Councils should allocate further land for development, focusing on sites that do not require significant additional infrastructure before housing delivery can commence. Accordingly, the New Settlement allocations should be supported by additional allocations on the Edge of Cambridge, such as Land East of Gazelle Way, Cherry Hinton, alongside proportionate allocations on the edge of sustainable villages including medium-scale sites across the District. This approach would mitigate the risks of delays in delivery on these large strategic sites and ensure a more balanced, responsive and deliverable supply.
Endurance Estates has consistently promoted sites across Greater Cambridge for development, and several of these sites can deliver early in the Plan period to ensure a robust 5YHLS position. These include:
 Land East of Gazelle Way, Cherry Hinton (Site ID 115222; HELAA ID 40250).
 Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
 Land at The Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
 Land at Elbourne Way, Bassingbourn (Site ID 116006, HELAA ID 40227)
 Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)
 Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)

Endurance Estates therefore considers that the Housing Trajectory at Appendix D is unsound on the basis that the housing trajectory includes insufficient sites with too much reliance placed on delivery at large scale New Settlements. As a result, it is considered to that the Housing Trajectory and associated housing supply is not positively prepared, justified, effective or consistent with national policy and is unsound.

It is therefore considered that the restrictions on the scale of growth at different levels of the settlement hierarchy should be deleted.

Whilst the broad objective of this policy is supported, Endurance Estates objects to Policy S/SH as proposed in the Regulation 19 Plan and consider that it is not positively prepared, justified, effective or consistent with national policy and is therefore unsound.

Draft Policy S/SH sets out the groupings of settlements into categories that reflect their scale, characteristics, and sustainability. The settlement hierarchy is proposed to direct housing to the most sustainable locations and control windfall development in the least sustainable locations.

The Settlement Hierarchy seeks to direct the majority of new housing to Cambridge first, then Edge of Cambridge followed by the New Settlements. It is acknowledged that Cambridge is constrained by a lack of available sites, however, as outlined in Endurance Estates’ representations to Policy S/DS, the majority of development is proposed to be directed to the New Settlements (the third tier). This overlooks sustainable and available Edge of Cambridge locations, where there is capacity to provide additional housing and employment land in sequentially preferable locations in terms of sustainability.

In particular Endurance Estates objects to the arbitrary indicative limits on the scale of housing developments set out within the Policy. The indicative housing limits do not ensure the continued vitality of the villages, nor recognise their sustainability for proportionate and controlled housing growth.

Policy S/SH currently restricts Minor Rural Centres to residential development up to an indicative maximum size of 30 dwellings and Group Villages to an indicative maximum scheme size of 8 dwellings with up to 15 in ‘exceptional’ circumstances.

For Group Villages, as mandatory Affordable Housing provision is only triggered on Major sites, the Council are relying exclusively on goodwill and rural exceptions sites to meet affordable housing needs, which is not considered a robust approach to meeting the affordable housing needs of the District’s villages.

These arbitrary indicative limits on the scale of housing developments set out by the Draft Policy have not been properly justified. They are unlikely to ensure the continued vitality of the villages and do not recognise their individual needs or the sustainability for proportionate and controlled housing growth. Moreover, the Draft Plan proposes very few new housing sites within the more sustainable villages, but where there is capacity to provide additional housing which could come forward in advance of the strategic New Settlement sites and support a more balanced, robust and deliverable housing supply. As a result, the policy is not considered to be positively prepared or justified, as it will result in unmet housing needs across the villages of the District. It is therefore considered to be unsound.

As set out at Paragraph 83 of the NPPF (December 2024), housing should be located where it will enhance and maintain rural communities, and planning policies should identify opportunities where villages can grow and thrive. However, as currently drafted, Policy S/SH is hugely restrictive and risks undermining the vitality and sustainable growth of village settlements by placing somewhat arbitrary limits upon housing development.
The rural areas of South Cambridgeshire are ageing rapidly, Cambridgeshire Insight estimate that the greatest increase in population will be in the elderly population, with a 55% increase in the 80-84 age population and a 45% increase in the over 85s. This rapid aging is a challenge to villages which do not see any growth, and risks jeopardising the ongoing provision of key services including rural schools and local shops –– jeopardising continued provision of one of the key features which make them sustainable locations to live.

A controlled and proportional level of growth is the best way to ensure the continued vitality of rural villages. In this context, Paragraph 82 of the NPPF confirms that in rural areas, “planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs”, whilst Paragraph 83 states that “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”. The current Draft Plan is not considered to sufficiently address local needs or circumstances and is therefore not in accordance with national policy.
Sites should preferably be brought forward through the plan-led process, however if not, policies such as Policy S/SH should be sufficiently flexible to ensure that proportionate development that can be supported by existing or planned infrastructure can come forward.

Whilst it is acknowledged that the Plan will be examined under the December 2024 NPPF, it is important to have regard to Annex A of the August 2026 NPPF which states that “development plan policies (or parts of those policies) which are materially inconsistent with national decision-making policies in this Framework should be given very limited weight”. In this regard, Endurance Estates contend that the blanket and arbitrary numerical restrictions on residential development within settlements are inconsistent with national policy and are not justified.

The 2026 NPPF includes Policy S4, which establishes a presumption in favour of development within settlements. Further, S5 establishes a similar framework for determining developments outside settlements. Neither S4, nor S5 of the NPPF include any reference to limiting or restricting development inside villages, and on the contrary the NPPF actively promotes, in Policy L3, the optimisation of site capacity through higher densities in appropriate locations. An arbitrary limit of 8 dwellings in Group Villages and 30 in Minor Rural Centres, is not considered to accord with this aim and so is not in accordance with National Policy.

Accordingly, the arbitrary numerical limits on development expressed in the hierarchy are unsound as they are not justified, effective or consistent with national policy and would only attract ‘very limited weight’ following adoption of the Plan. It is therefore considered that the restrictions on the scale of growth at different levels of the settlement hierarchy should be deleted.

Endurance Estates consider that the proposed Policy wording should be amended to allow for development outside the defined settlement boundaries where there is an evidenced unmet need and sites are well related to the settlement in accordance with Policy S5 along with Policies GB6, GB7 and GB8 of the NPPF. This will ensure that Policy S/DE is consistent with national policy following adoption. Endurance Estates suggest that Part 2 of the Policy is therefore deleted.

Endurance Estates objects to Draft Policy S/DE and considers that it is unsound due to the lack of flexibility in the policy and on the grounds that as a result it is not justified nor consistent with National Policy.
Part 2 of the Policy as currently drafted, states that by default development outside the development extents will not be permitted except for allocations in Neighbourhood Plans, Rural Exceptions Sites, Agricultural Development or where supported by other policies of the plan.
The wording of the proposed policy is effectively identical to that of South Cambridgeshire’s Local Plan (2018) Policy S/7. However, since adoption of the 2018 Plan, the national policy position has evolved significantly. The 2026 NPPF includes Policy S5, which establishes a framework for determining developments outside settlements. Part 2 of S/DE is considered to be significantly more restrictive than Policy S5 of the 2026 NPPF.
Whilst it is acknowledged that the Draft Plan will be examined under the December 2024 NPPF, it is important to have regard to Annex A of the August 2026 NPPF which states that “development plan policies (or parts of those policies) which are materially inconsistent with national decision-making policies in this Framework should be given very limited weight”.
Accordingly, Endurance considers that Policy S/DE is unsound as it is not consistent with national policy and as such will only attract ‘very limited weight’ following adoption. The impacts of the draft Policy upon potential windfall sites of this are compounded by the lack of residential allocations across many the sustainable villages of the district (as referenced in the wider Endurance representations). As a result, there is a substantial risk that over the plan period, many of the villages will see their populations stagnate or even decline, with little-to-no affordable housing delivered across the period, placing unnecessary strain on local services and affordability.
It is considered that the inflexibility of this policy will make achieving the neighbourhood housing need outlined in Appendix C difficult to achieve in reality. Flexibility would also aid in ensuring Greater Cambridge’s housing delivery can maintain a sufficient 5-year supply across the Local Plan period.
Accordingly, Endurance Estates contend that Policy S/DE is unsound as it is not consistent with national policy and as such will only attract ‘very limited weight’ following adoption.

The wording of the Policy should be amended such that if confirms that, in addition to a judgement, a demonstrated lack of a five-year housing land supply or unfavourable HDT result would also trigger the steps outlined in Policy S/MO. This will ensure that Policy S/DE is consistent with national policy following adoption.

Endurance Estates strongly objects to Draft Policy S/MO and considers that it is unsound on the grounds that it lacks specific consequences and timeframes in the event that housing and employment policies are not being achieved. As a result, it is considered that the proposed policy is not effective or consistent with national policy and is unsound.

Whilst Appendix E (Monitoring Framework) is acknowledged, it is considered that the wording of Policy S/MO is not sufficiently specific with regards to the triggers and consequences of policies “not being achieved”. The current wording of the supporting information is subjective and implies a judgement from the Council as to whether policies are coming forward in a “timely manner”.

It should be clarified that, in addition to a judgement, a demonstrated lack of a five-year housing land supply or unfavourable HDT result would also trigger the steps outlined in Policy S/MO which would align with Policy S5 of the 2026 NPPF whereby evidence of unmet need would trigger the positive presumption in favour of sustainable development.

The Sustainability Appraisal should be updated in order to consider the social, economic and environmental effects of higher levels of housing development to further support economic growth within the Greater Cambridge economy in accordance with Government aspirations for the area. This should consider growth the implications of a housing requirement in the region of 66,000 new homes to begin to rebalance homes and jobs and reduce in-commuting.

The Sustainability Appraisal should also give further consideration to the social and economic implications of different levels of growth within the villages, taking account of those which would benefit from planned infrastructure improvements.

Endurance Estates objects to the Sustainability Appraisal prepared in support of the Proposed Submission Local Plan as it is considered that the assessment has not adequately considered the reasonable alternatives. As a result, it is considered that the Sustainability Appraisal is unsound due to flaws in the way that the reasonable alternatives have been considered, it is not justified or consistent with National Policy.

Land East of Gazelle Way (40250)

Endurance Estates acknowledge and are mostly supportive of the adjustments made to the Table 4.4 (Summary of SA findings for site options in Edge of Cambridge: Green Belt). The amendments made mostly recognise Endurance Estates’ previous comments and result in a significantly more positive assessment of the Site at Land East of Gazelle Way (40250) as shown by those topics highlighted green below.

*Please refer to the PDF version of these representations for a comparison between the HELAA assessments*
However, the summary of the assessment in Table 4.4 still outlines uncertainty with regards to Landscape & Townscape, Historic Environment, Efficient use of Land, Minerals and Water, though these uncertainties affect the vast majority of the sites assessed, including some of the Plan’s most high-profile allocations at the Biomedical Campus and the Cambridge Airport site.

Endurance Estates acknowledge the responses to Endurance Estates’ previous representations which are outlined at Paragraph 19 of Appendix A. With respect to Land East of Gazelle Way (40250). The LUC response does not challenge Endurance’s assessment that the SA assesses the site positively in terms of its sustainability. Instead, the SA defers to the Council to make allocation decisions. The LUC response states that “The Sustainability Appraisal provides an evidence-based assessment of sites identified and tested through the plan-making process but does not determine site allocation, that is the role of the plan-makers”. LUC refer to Appendix E (‘Council’s justification for selecting the spatial strategy and site allocations for the plan’) for confirmation as to why individual sites are not allocated.

For Land East of Gazelle Way (40250), Appendix E states the following: “Development would result in coalescence between Cambridge, Teversham and Fulbourn and encroachment into the countryside. The Cambridge Green Belt Study (2026) identifies that release of land in this area would result in a moderate high/ high/ very high level of harm to the Green Belt. While a small part of the site is considered to be potential grey belt, the proposed development strategy has identified alternative locations to meet development needs, and it is not considered that there are exceptional circumstances for a Green Belt release in this location”. Accordingly, it can be concluded that, despite the SA’s positive assessment of the sustainability of Land East of Gazelle Way, the site is not allocated principally due to its Green Belt designations, which themselves can be addressed in turn.

It is therefore clear that some of the most sustainable sites, as per the Sustainability Appraisal, are not proposed for allocation due to the Green Belt designation. This is concerning especially given that Endurance Estates have provided evidence to demonstrate that Land East of Gazelle Way is Grey Belt which is acknowledged for a small part of the site in the Council’s assessment.

Consideration to Edge of Cambridge (Green Belt) sites appears to have been considered through Spatial Option 10, which was introduced to the Options in the ‘Additional Strategic Spatial Options (2021)’ and again in 2025 through Option 10a (Hybrid spatial strategy including Ede of Cambridge Gren Belt and expanding Cambourne) and finally in 2026 as Option 10b (Hybrid spatial strategy including Edge of Cambridge Green Belt and expanding Cambourne (but with no further development at North East Cambridge).

Appendix C of the SA confirms that Options 10 and 10a were not clearly rejected because they performed materially worse overall than the preferred strategy. It cannot be said that the SA states that that the options were unsustainable. The preferred option was concluded to be preferable with regards to Climate Change and Transport, seemingly due to the committed enhancements of East West Rail and the bus rapid transit improvements which benefit the A428 and Cambourne area. The SA does not provide any strong reasons against the pursuit of Option 10, 10a or 10b.

General Comments

It is considered that the Sustainability Appraisal has failed to fully consider the issues with regard to the balance between homes and jobs within Greater Cambridge and the effects of different levels of growth with regard to their social and economic effects. The higher housing growth options of circa 56,000 new homes over the Plan period are still relatively low and the effects of different levels of housing growth to reduce in-commuting and support the Greater Cambridge economy has not been fully assessed.

In terms of the allocation of developments in the Rural Centres, Minor Rural Centres and other villages of the district, the SA broadly assesses this under Option 5 (Dispersal – villages). The primary observations of this option are that the villages lack higher-order services, weaker public transport, car dependency and a lack of critical mass to deliver key infrastructure. These criticisms are all broadly accepted by Endurance Estates, however the LPA’s reaction to this assessment is to allocate only very limited development across the lower tier settlements of the district, which Endurance Estates contend is a dramatic and unnecessary overreaction which is not justified by the evidence provided.

Endurance Estates also contend that strategic transport enhancements have been considered inconsistently through the assessment. In particular, it is noted that the assessment of the Grange Farm allocation (S/GF) includes specific reference to the CSET Busway improvement, however it is not clear from the assessment whether this has been carried over into the appraisal of Spatial Options 5 and 6 and the site-specific level. For Endurance Estates’ site at Horseheath Road, Linton, the strategic transport enhancements, including the Linton Greenway and CSET bus and active transport scheme both materially improve the accessibility and sustainability of the site, and it is not clear that these have been fully accounted for in the updated SA.

Southern Cluster

Moreover, the Sustainability Appraisal notes at Paragraph 4.42 that the ‘Southern Cluster’ which includes Linton, would ensure that “housing is well-located in relation to existing centres of employment”. Paragraph 4.35 continues “the scale of development in the Southern cluster should be sufficient to also provide some new services and facilities”. Paragraph 4.49, also states that development in the ‘Southern Cluster’ villages, may “help to boost the vitality and viability of village services and facilities, which is particularly likely to benefit older people and the less mobile”. The Southern Cluster is acknowledged in the SA to benefit from ‘very good’ public transport access. These comments and acknowledgements are considered to chime with the requirements of Policy HO6 of the NPPF 2026, to allocate sufficient dwellings to support rural vitality, and are strongly endorsed by Endurance Estates.

Endurance Estates assert that a balanced strategy, which includes a sustained but proportional level of growth within the villages of the district, is the simplest and most effective way of ensuring the continued provision of essential services which are relied upon by existing residents and enhancing the sustainability of these villages further. The SA does not rule out this strategy, and on the contrary, the responses from LUC on Page 58 of the SA defers the strategy to the LPA. Regrettably, despite the good evidence that growth would support existing services, growth in the ‘Southern Cluster’ has largely been overlooked in the current proposed strategy. It is not considered that the LPA’s choice in this matter is robustly supported by the SA.

As a result, it is considered that the Sustainability Appraisal is not sound due to flaws in the way that the reasonable alternatives have been considered and the subsequent conclusions drawn and taken forward as part of the Plan making process. Accordingly, it is not justified, effective or consistent with National Policy.