Greater Cambridge Local Plan: Proposed Submission

The Green Belt should be further reviewed to identify suitable Grey Belt and other suitable sustainable Green Belt sites on the Edge of Cambridge which can be allocated for new housing to meet the areas housing needs as the next most sustainable location for growth after the Cambridge Uran Area. This should include the allocation of Land East of Gazelle Way, Cherry Hinton (Site ID 115222; HELAA ID 40250) for a residential-led development of circa 1,500 new homes.

In any event, The Policy should be amended to reflect the requirements of the Green Belt policies in the NPPF in order to ensure consistency with National Policy.

Endurance Estates object to draft Policy S/DS 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.

In accordance with paragraphs 145-147 of the NPPF 2024 (Policy GB2 and GB3 of the NPPF 2026) and following the updated Planning Practice Guidance issued in February 2025, the Councils are required to review Green Belt boundaries to support the emerging Local Plan. To this end, on 27th February 2025, it was announced that Greater Cambridge Planning had received £140,000 to facilitate a comprehensive review of the Green Belt to support the emerging Local Plan. It is not clear how this has been spent, other than a light-touch update to the previous Assessment.
Endurance Estates are concerned that the further evidence provided within the Greater Cambridge Green Belt Assessment – Review Following Changes to National Policy and Guidance (July 2026) prepared by LUC represents only a minor update to the 2021 Green Belt Assessment, and accordingly, the Plan is still largely based on evidence which is now over 5 years old. LUC’s July 2026 Update makes only minor updates and concludes that there is very little Grey Belt land or other land suitable for release from the Green Belt. The document, having prepared late in the preparation of the Local Plan effectively seeks to retrospectively justify a Development Strategy that has already been determined by suggesting that the changes in Green Belt policy in the NNPF and PPG make no material difference to the previous conclusions despite these representing the biggest change in Green Belt policy since its inception in the 1950s.
Notwithstanding the above, the Draft Policy S/GB maintains the additional ‘Cambridge Green Belt Purposes’, which effectively grant greater protection to Green Belt within Greater Cambridge than National Policy affords.
Indeed, Cambridge Green Belt Purpose C prevents “communities in the environs of Cambridge from merging into one another and with the city”. This is not consistent with National Policy, and Endurance Estates contend that it is a much higher bar than afforded by the NPPF, which references “neighbouring towns” only and confirms that this protection is not intended to cover villages. The NPPF therefore deliberately limits the Green Belt purpose to the prevention of coalescence between towns and cities, rather than all Green Belt settlements.
Not only is Cambridge Purpose C a duplication of NPPF Green Belt Purpose B, it goes significantly further. The justification for this is not clear form the evidence base. The 2026 NPPF instead outlines, in Policy S2(c), that designations should be made to safeguard gaps between settlements where necessary to maintain and separate identities of the settlements. Clearly, the intent is for this to be a site and settlement specific measure, rather than a blanket application.
A less restrictive approach would help to accommodate growth in the most sustainable locations of Greater Cambridge, helping to accommodate a portion of the Government’s aspiration for the growth of the City.
As with previous representations, Endurance Estates remain concerned that the draft Green Belt policy will be fundamentally flawed and risk being unsound, ineffective and inconsistent with national policy.
Endurance Estates propose the following revisions to the S/GB Policy:
1. A Green Belt will be maintained around Cambridge in accordance with national Green Belt policy.
2. The detailed boundaries of the Green Belt are defined on the Policies Map.
3. In considering the future role and function of Green Belt land around Cambridge, regard will be had to:
a. The nationally defined Green Belt purposes set out in Policy GB2 of the National Planning Policy Framework;
b. The contribution of Green Belt land to the setting and special character of the historic city of Cambridge; and
c. The need to support a sustainable pattern of development consistent with the spatial strategy of the Local Plan.
4. Development proposals within the Green Belt will be determined in accordance with the Green Belt policies of the National Planning Policy Framework.
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 to support additional housing growth beyond the minimum currently identified and achieve a more balanced and sustainable housing land supply which locates growth in the second most sustainable location, helps to address unmet market and affordable housing needs in Cambridge and mitigates the risk of delayed delivery from the New Settlements. 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.
Notwithstanding the conclusions in the LUC Green Belt Study, Endurance Estates consider their land at East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250) to be Grey Belt land having regard to the definition in the Annex B of the NPPF 2026, in that it does not contribute strongly to Green Belt Purposes (a), (b) or (d). 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, the site makes a moderate contribution to Purpose A and does not therefore contribute strongly to Purpose A.
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 Paragraph 156 of the NPPF (Policy GB8 of the NPPF 2026).
Initial technical investigations on the indicative design confirm that 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.
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. As stated in Policies GB6 and GB7 of the NPPF, development which is Grey Belt and which complies with the Golden Rules should be given significant weight in favour of granting permission.
It is considered that the housing and employment needs of the nationally significant Greater Cambridge economy represent exceptional circumstances that justify the release of land from the Green Belt.
Endurance Estates object to the draft Policy S/GB as it is considered that the Policy is unsound on the basis that it is not positively prepared, justified, effective or consistent with national policy when considered against the reasonable alternatives and evidence available.

The proposed housing in the ‘Rest of the Rural Area’ should be increased to meet the National Requirements as set out in HO6 – namely, to allocate specific sites to meet at least 10% of the housing requirement; a further 10% for medium sites (up to 2.5ha) along with other proportionate allocations to meet local needs with sufficient sites to support the village economies, local services and facilities.

Draft Policy S/RRA allocates specific sites within the rest of the Rural Area to help meet the development needs across Greater Cambridge. Endurance Estates, objects to the draft Policy on the basis that the housing allocations identified within the Rest of the Rural Area are insufficient to meet local housing needs in villages, and further, that it omits Endurances sites for residential development. The Policy is therefore not considered to be positively prepared, justified, effective or consistent with national policy and is unsound.

Endurance Estates consider that the housing allocations proposed in the Regulation 19 Proposed Submission Local Plan across the rural area are insufficient to meet local housing needs in the villages of the District The lack of new housing site allocations in the villages within the Rural Area reflect wider concerns set out in our responses to other Policies (S/JH and S/DS) that confirm the Plan is not providing for sufficient number of new homes in the right places.

In addition to the inherent spatial imbalance which exists due to the lack of significant allocations south and east of the City, the Development Strategy being pursued, has resulted in very few new housing allocations in the ‘Rest of the Rural Area’, which are largely overlooked in favour of significant New-Settlement allocations.

Endurance Estates are also concerned that the Plan does not appear to meet the requirements of Part (a) of Policy HO6 of the NPPF 2026 which requires the Council to allocate 10% of their housing requirement on sites no larger than 1 hectare, and a further 10% between 1-and-2.5 hectares.

Further, the Part (b) of Policy HO6 requires the Councils to 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”. The Government’s intention is therefore clear - growth within villages is essential to ensure they continue to be vibrant, inclusive communities with new opportunities for residents to stay in those communities. Such sites are necessary as part of a blended, robust housing land supply to meet needs across the whole of Greater Cambridge, and to deliver a spatial development strategy that is positively prepared, justified, effective and consistent with national policy.

The Regulation 19 Plan makes only a handful of allocations within the ‘Rest of the Rural Area’.

• S/RRA/ML (Moor Lane) – 20 dwellings
• S/RRA/H (Highfields Phase 2) – 65 dwellings
• S/RRA/ (Cambridge Road, Melbourn) – 125 dwellings
• S/AMC/FD (Land Settlement Association Estate Area of Major Change) – No clear use
• S/AMC/HIS (Histon and Impington Station) – Mixed use – no quantum confirmed
As set out above, across the S/RRA Policies, there are only very limited allocations for residential development, with most being for employment, or unspecified mixed uses. The residential allocations are confined to Moor Lane, Highfields and Melbourn, totalling just 210 homes across the District - equal less than 0.5% of the identified housing requirement. Endurance considers this to be woefully insufficient to meet the needs of the villages of the district and does nothing to support the local economies and services within these settlements.

It is considered that the housing allocations identified within the Rest of the Rural Area are not aligned with the settlement hierarchy in terms of distribution and scale of development.

As mentioned within our representations to Policy S/DS, there is a strong focus within the Draft Local Plan on the delivery of strategic sites, particularly New Settlements. Whilst it is recognised that strategic sites are capable of delivering large numbers of homes and making a meaningful contribution to meeting identified development needs, the proposed New Settlements make up almost half of the planned housing supply. This reliance on large strategic sites places an undue reliance and significant dependence on such sites and risks under delivery in the face of any delays to their delivery, particularly as many of these sites are subject to significant infrastructure delivery requirements.

Over-reliance on Windfall

Paragraph 2.41 of the Regulation 19 Plan confirms that the Councils intend to rely heavily upon windfall to meet the small-sites requirement. The Councils contend that allocating the full amount on specific identified sites would be “extremely challenging”. Endurance Estates contend that this is not a sound strategy and Policy HO6 is clear that the Councils should be allocating specific sites to meet this need. Allocation of a small number of additional sites in the Rest of the Rural Area, such as Endurance Estates’ sites below, would go some way to meeting this need.

The arguments for not allocating specific sites, such as the highly-sustainable Endurance Estates sites outlined below, in is not justified. The Councils state that allocation of the full small-sites requirement would direct “a significant portion of growth to less sustainable locations where levels of car use would be higher, negatively impacting our response to the challenges of net zero carbon and Climate Act obligations and undermining our vision and strategic priorities”. Notwithstanding this, the reliance upon windfall to meet this need appears to be in conflict with this statement.

The Policy as currently drafted risks artificially constraining housing provision outside of Cambridge and the New Settlement allocations. In doing so, the Plan risks worsening affordability pressures, already present within the District, whilst increasing the need to commute and restricting labour supply. Ultimately, in failing to deliver sufficient new homes in the villages of the District – in addition to those in Cambridge and the new settlements – the Council are constraining business and economic growth. This is at odds with the stated ambitions of the Government, and the Councils’ own evidence and as such will fail to support the planned economic growth of the City region.

In relying upon windfall developments to exclusively meet the housing needs of the majority of the villages of the District, and when considered in combination with S/SH - which Endurance have also made representations on within this submission – the Council are restricting the ability of developments to meet the affordable needs of the villages. Policy S/SH currently restricts Local Service Centres to “an indicative maximum scheme size of 30 dwellings” and Group Villages to “an indicative maximum scheme size of 8 dwellings” with up to 15 in ‘exceptional’ circumstances. As mandatory Affordable Housing provision is only triggered on Major sites, the Council are relying exclusively on goodwill and rural exceptions sites. This is not considered a robust approach to meeting the affordable housing needs of the District’s villages.

Meeting Local Housing Needs

The evidence base does not assess affordable housing need within the District's villages, which raises the question of whether the Plan and Policies can be said to address local housing needs and whether they have been properly planned for.
The Plan itself acknowledges that locating homes closer to employment can reduce commuting. Sustainable villages, including those benefiting from committed transport improvements, can make a meaningful contribution to this objective. The absence of significant housing allocations in such locations therefore represents a missed opportunity to support sustainable travel patterns.
The proposed housing strategy also lacks sufficient diversity. Only a small proportion of housing need is expected to be delivered through specific small and medium-sized allocations, with significant reliance on windfalls and large strategic sites. This approach is inconsistent with the Government's increasing emphasis on the role of small and medium-sized sites in boosting housing delivery and market diversity. Evidence consistently shows that smaller sites are delivered more quickly and can improve resilience within the housing trajectory.
The Plan should therefore identify additional small and medium-sized allocations in suitable village locations and ensure new settlements are supported by sufficient employment opportunities to create balanced and sustainable communities.

In particular, Endurance Estates strongly objects to Draft Policy S/RRA on the basis that it omits the following proposed site allocations:

• 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)
These sites are considered in turn below.
Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
Endurance Estates have consistently promoted Land South of Horseheath Road and sought to provide updated technical information at every given opportunity. The 2025 HELAA relating to the landscape impact states that the “Site is highly sensitive in landscape terms and development in this location would be highly visible, creating adverse impacts on landscape character and local views. These impacts are significant when considered cumulatively alongside other development on adjacent land”. It is not clear on what basis this conclusion was reached, as detailed Landscape and Visual Impact Assessments have concluded that development of the site can be sufficiently mitigated through a considerate, landscape-led design and planting scheme.

The July 2026 Sustainability Appraisal Appendix E (Justification for selecting the spatial strategy and site allocations for the plan) states the reason for not proposing the site for allocation as follows:
“The landscape assessment has been changed from Red to Amber. However, the site sits on a slightly more elevated parcel of land compared to its surroundings, which will result in development being more visible. The required landscape mitigation would reduce the capacity of the site. There are a number of sites recently developed or committed on the edge of Linton. There are other sites considered more appropriate for allocation.”

It is considered to be significant that this response does not challenge the sustainability of the site. Further, Endurance Estates contend that the capacity of the site is demonstrated through the supporting plans and application materials which were submitted to Greater Cambridge Planning in support of the Outline Planning Application (Ref: 26/00415/OUT) for the Site in February 2026. Following submission of the Outline Planning Application, it is demonstrated that there are no significant or insurmountable constraints which should preclude development of the site.

As a Minor Rural Centre, Linton is demonstrably a sustainable settlement. Linton benefits from an Infant, Junior and Secondary Schools, a Library, several shops and cafes, public houses, a GP Surgery, dental practice, and an excellent range of sports and recreation facilities, including a skate park, swimming pool and sports pavilion. It is therefore considered that the site, and by extension the village of Linton, benefits from sufficient accessibility to essential shops and services, alongside the ability to travel sustainably further afield for a full array of services in both the surrounding villages and Cambridge.

Linton also now benefits from The Linton Greenway, which is now significantly advanced, providing a quality active travel route between Linton and the Abingtons (including Granta Park) and the planned CSET2 Busway scheme, which will provide fast and direct public transport connections into Cambridge and the Biomedical Campus from a new Travel Hub on the A11 Junction at Fourwentways. The Secretary of State has confirmed the CSET Busway is expected to commence Inquiry in October 2026. Both schemes will materially improve the sustainability of the settlement in a way which we consider has not been reflected in the assessment of the village’s potential to accommodate growth sustainably.
It is expected that subject to approval, the CSET scheme will come forward as envisaged prior to or in a similar timeframe to the development of the site.

The supporting text to Policy S/DS: Development Strategy outlines that “We [Greater Cambridge] also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion”. This acknowledgement is endorsed by Endurance Estates as recognition of the sustainability of villages in the Southern Cluster, which includes Linton. Despite this sensible admission, it makes the lack of any residential allocations within Linton difficult to understand, particularly with the transport enhancement schemes being brought forward by GCP with the express purpose of improving the accessibility of the Village to employment sites.

Endurance Estates contend that the omission of Land South of Horseheath Road fails to recognise Linton’s accessible location and the likelihood that this will shortly be enhanced through planned public transport improvements, along with the good level of existing service provision. The site and village as a whole is outside of the Green Belt and the identified landscape constraints are capable of being overcome through a landscape-led design approach

Linton is therefore demonstrably a sustainable location capable for accommodating further housing growth to meet the identified local need and its allocation would be consistent with the strategy of focussing growth in the Rural Southern Cluster, close to existing employment sites. In this regard, Greater Cambridge should allocate Land South of Horseheath Road for a sustainable development of approximately 100 market and affordable homes within the village.

The Site remains Available, Achievable and Suitable for residential development.

Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)

Endurance Estates objects strongly to the proposed Inset Map for Balsham on the grounds that it does not propose allocation of Land at Old House Road for residential development. The Policies Map proposes no residential allocations within the village, Endurance Estates are promoting Land to the Rear of Old House Road, Balsham which is considered capable of accommodating a scheme of approximately 25 new dwellings.

Crucially, draft Policy S/SH states that “limited development will help maintain remaining services and facilities and provide for affordable housing to meet local needs”. This acknowledgement is strongly supported by Endurance Estates, however the lack of any allocated development to ensure the long-term vitality of the village’s facilities is disappointing.

Balsham had a population of 1,623 as of the 2021 Census, which represents an approximate 1% decrease on the 1,641 residents recorded at the 2001 Census. This contrasts starkly with the wider South Cambridgeshire district, which grew by just under 25% in the same time period. This stagnation places the village’s existing services at risk of further decline. As correctly identified by the supporting text to Policy S/SH, additional growth in villages such as Balsham is key to maintaining their vitality. Simply, without growth, the range of shops and essential services is likely to continue to deteriorate.

In terms Land to the Rear of Old House Road, there were no significant issues which cannot be mitigated through the scheme design which were raised in the 2021, 2023 or 2025 HELAA documents.
Endurance Estates contend that the Inset Map for Balsham should be urgently updated to ensure that controlled growth can come forward, in support of essential services through the allocation of sites such as Land to the Rear of Old House Road.

The Site remains Available, Achievable and Suitable for residential development.





Land off the Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
Land off Elbourn Way, Bassingbourn (Site ID 116006, HELAA ID 40227).
Endurance Estates objects strongly to the proposed Inset Map for Bassingbourn on the grounds that it does not propose allocation of either Land off the Causeway, or Land off Elbourn Way for residential development. The Policies Map proposes no residential allocations within the village, despite it being a sustainable Minor Rural Centre. Greater Cambridge recognises that the village plays a role in providing services and facilities for a rural hinterland; however, the lack of allocations to secure controlled growth moving forward puts existing services at risk of decline.

Bassingbourn had a population of 2,351 at the 2021 Census which represents a marked decrease on the 3,090 residents that lived in the village at the time of the 2001 Census. This decline is in stark contrast with South Cambridgeshire, which grew by just under 25% in the same time period. There is therefore an urgent need to protect the vitality of the village to secure the ongoing provision of shops, services and community facilities. The Village currently hosts a good range of shops and services including a Spar Convenience Store, Public Houses and a community centre. The Village also benefits from Bassingbourn Primary and Bassingbourn Village College. Without additional growth in villages such as Bassingbourn, which play key roles in the delivery of shops and services for rural areas of South Cambridgeshire, the breadth and quality of key shops and services is likely to deteriorate, ultimately harming the sustainability of the settlement in the long term.

The Inset Map for Bassingbourn should be updated to reflect the role of the village as a Minor Rural Centre. Proportional and sympathetic extensions to the village, such as those proposed at Land off the Causeway and Land off Elbourn Way, are the best and most effective way to securing the continued viability of essential services and facilities and maintaining the vitality of the village in accordance with paragraph 83 of the NPPF.

The Site remains Available, Achievable and Suitable for residential development.

Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)
Endurance Estates objects strongly to the proposed Inset Map for Orwell on the basis of the omission of a site specific policy allocating Land at Hillside, Orwell for a residential development.

Orwell is categorised as a Group Village under draft Policy S/SH. The village has experienced moderate growth since the 2001 Census, increasing by approximately 6%. However, this is significantly below the growth rate of South Cambridgeshire, which saw population growth of just under 25% during the same period. As of the 2025 Regulation 18 Consultation, there are no residential allocations proposed within the village.

Orwell benefits from a Primary School, Public House, Post Office, Convenience Store and a Village Hall. The Village also has a good bus connection to Cambridge for a wider range of services.

Land at Hillside, Orwell, is promoted by Endurance Estates for a landscape-led development of approximately 26 dwellings. The 2025 HELAA did not assess the site as it was deemed to “not align with the wider Local Plan Strategy”. Endurance Estates consider that this fails to consider the contribution that the Site could make towards a controlled and proportionate growth of the Village in order to support essential services and facilities to maintain the vitality of the village in accordance with paragraph 85 of the NPPF.

Since the development at Hurdleditch Road was approved in 2016 (S/3190/15/OL), no further major schemes have been approved in the village. Partly as a result of the lack of site allocations there within the Adopted Local Plan.

Department of Education records indicate that the Petersfield C of E Primary School has 134 pupils on roll and a capacity of 210, indicating that the school is currently operating at around 64% capacity. This suggests there is capacity for growth within the village, which would help safeguard existing services for the benefit of current and future residents.
The Inset Map for Orwell should be updated to reflect the capacity of the village for a controlled and proportionate level of growth to support the Village’s services. This should include, as a minimum, Land at Hillside, Orwell for a residential development of circa 26 dwellings.
The Site remains Available, Achievable and Suitable for residential development.
Conclusions

Accordingly, for the reasons outlined above, Endurance Estates contends that Policy S/RRA is unsound. By focusing growth almost exclusively on strategic sites and constraining the range and distribution of housing growth by largely excluding growth at sustainable villages, the Plan risks:
• Failing to meet local market and affordable housing needs.
• Increasing commuting and associated congestion and emissions.
• Undermining the vitality and viability of village services and facilities.
• Over-reliance on a small number of large allocations, reducing delivery resilience.
• Failing to capitalise on committed transport investments, including: GCP Greenways and the CSET Busway Mass-rapid transit scheme;.
• Exacerbating affordability pressures and undermining the labour supply and economic growth ambitions of Greater Cambridge.

Accordingly, the policy is not positively prepared, justified, effective or consistent with national policy.

The allocation of a small number of additional, smaller and more easily deliverable sites in the Rest of the Rural Area, such as Endurance Estates sites listed above, would go some way to meeting this need, whilst also strengthening the Council’s slim 5-year housing land housing supply buffer, which by the Council’s own admission, is marginal upon adoption of the Plan.

The proposed housing in the ‘Rest of the Rural Area’ should be increased to meet the National Requirements as set out in HO6 – namely, to allocate specific sites to meet at least 10% of the housing requirement; a further 10% for medium sites (up to 2.5ha) along with other proportionate allocations to meet local needs with sufficient sites to support the village economies, local services and facilities.

Draft Policy S/RRA allocates specific sites within the rest of the Rural Area to help meet the development needs across Greater Cambridge. Endurance Estates, objects to the draft Policy on the basis that the housing allocations identified within the Rest of the Rural Area are insufficient to meet local housing needs in villages, and further, that it omits Endurances sites for residential development. The Policy is therefore not considered to be positively prepared, justified, effective or consistent with national policy and is unsound.

Endurance Estates consider that the housing allocations proposed in the Regulation 19 Proposed Submission Local Plan across the rural area are insufficient to meet local housing needs in the villages of the District The lack of new housing site allocations in the villages within the Rural Area reflect wider concerns set out in our responses to other Policies (S/JH and S/DS) that confirm the Plan is not providing for sufficient number of new homes in the right places.

In addition to the inherent spatial imbalance which exists due to the lack of significant allocations south and east of the City, the Development Strategy being pursued, has resulted in very few new housing allocations in the ‘Rest of the Rural Area’, which are largely overlooked in favour of significant New-Settlement allocations.

Endurance Estates are also concerned that the Plan does not appear to meet the requirements of Part (a) of Policy HO6 of the NPPF 2026 which requires the Council to allocate 10% of their housing requirement on sites no larger than 1 hectare, and a further 10% between 1-and-2.5 hectares.

Further, the Part (b) of Policy HO6 requires the Councils to 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”. The Government’s intention is therefore clear - growth within villages is essential to ensure they continue to be vibrant, inclusive communities with new opportunities for residents to stay in those communities. Such sites are necessary as part of a blended, robust housing land supply to meet needs across the whole of Greater Cambridge, and to deliver a spatial development strategy that is positively prepared, justified, effective and consistent with national policy.

The Regulation 19 Plan makes only a handful of allocations within the ‘Rest of the Rural Area’.

• S/RRA/ML (Moor Lane) – 20 dwellings
• S/RRA/H (Highfields Phase 2) – 65 dwellings
• S/RRA/ (Cambridge Road, Melbourn) – 125 dwellings
• S/AMC/FD (Land Settlement Association Estate Area of Major Change) – No clear use
• S/AMC/HIS (Histon and Impington Station) – Mixed use – no quantum confirmed
As set out above, across the S/RRA Policies, there are only very limited allocations for residential development, with most being for employment, or unspecified mixed uses. The residential allocations are confined to Moor Lane, Highfields and Melbourn, totalling just 210 homes across the District - equal less than 0.5% of the identified housing requirement. Endurance considers this to be woefully insufficient to meet the needs of the villages of the district and does nothing to support the local economies and services within these settlements.

It is considered that the housing allocations identified within the Rest of the Rural Area are not aligned with the settlement hierarchy in terms of distribution and scale of development.

As mentioned within our representations to Policy S/DS, there is a strong focus within the Draft Local Plan on the delivery of strategic sites, particularly New Settlements. Whilst it is recognised that strategic sites are capable of delivering large numbers of homes and making a meaningful contribution to meeting identified development needs, the proposed New Settlements make up almost half of the planned housing supply. This reliance on large strategic sites places an undue reliance and significant dependence on such sites and risks under delivery in the face of any delays to their delivery, particularly as many of these sites are subject to significant infrastructure delivery requirements.

Over-reliance on Windfall

Paragraph 2.41 of the Regulation 19 Plan confirms that the Councils intend to rely heavily upon windfall to meet the small-sites requirement. The Councils contend that allocating the full amount on specific identified sites would be “extremely challenging”. Endurance Estates contend that this is not a sound strategy and Policy HO6 is clear that the Councils should be allocating specific sites to meet this need. Allocation of a small number of additional sites in the Rest of the Rural Area, such as Endurance Estates’ sites below, would go some way to meeting this need.

The arguments for not allocating specific sites, such as the highly-sustainable Endurance Estates sites outlined below, in is not justified. The Councils state that allocation of the full small-sites requirement would direct “a significant portion of growth to less sustainable locations where levels of car use would be higher, negatively impacting our response to the challenges of net zero carbon and Climate Act obligations and undermining our vision and strategic priorities”. Notwithstanding this, the reliance upon windfall to meet this need appears to be in conflict with this statement.

The Policy as currently drafted risks artificially constraining housing provision outside of Cambridge and the New Settlement allocations. In doing so, the Plan risks worsening affordability pressures, already present within the District, whilst increasing the need to commute and restricting labour supply. Ultimately, in failing to deliver sufficient new homes in the villages of the District – in addition to those in Cambridge and the new settlements – the Council are constraining business and economic growth. This is at odds with the stated ambitions of the Government, and the Councils’ own evidence and as such will fail to support the planned economic growth of the City region.

In relying upon windfall developments to exclusively meet the housing needs of the majority of the villages of the District, and when considered in combination with S/SH - which Endurance have also made representations on within this submission – the Council are restricting the ability of developments to meet the affordable needs of the villages. Policy S/SH currently restricts Local Service Centres to “an indicative maximum scheme size of 30 dwellings” and Group Villages to “an indicative maximum scheme size of 8 dwellings” with up to 15 in ‘exceptional’ circumstances. As mandatory Affordable Housing provision is only triggered on Major sites, the Council are relying exclusively on goodwill and rural exceptions sites. This is not considered a robust approach to meeting the affordable housing needs of the District’s villages.

Meeting Local Housing Needs

The evidence base does not assess affordable housing need within the District's villages, which raises the question of whether the Plan and Policies can be said to address local housing needs and whether they have been properly planned for.
The Plan itself acknowledges that locating homes closer to employment can reduce commuting. Sustainable villages, including those benefiting from committed transport improvements, can make a meaningful contribution to this objective. The absence of significant housing allocations in such locations therefore represents a missed opportunity to support sustainable travel patterns.
The proposed housing strategy also lacks sufficient diversity. Only a small proportion of housing need is expected to be delivered through specific small and medium-sized allocations, with significant reliance on windfalls and large strategic sites. This approach is inconsistent with the Government's increasing emphasis on the role of small and medium-sized sites in boosting housing delivery and market diversity. Evidence consistently shows that smaller sites are delivered more quickly and can improve resilience within the housing trajectory.
The Plan should therefore identify additional small and medium-sized allocations in suitable village locations and ensure new settlements are supported by sufficient employment opportunities to create balanced and sustainable communities.

In particular, Endurance Estates strongly objects to Draft Policy S/RRA on the basis that it omits the following proposed site allocations:

• 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)
These sites are considered in turn below.
Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
Endurance Estates have consistently promoted Land South of Horseheath Road and sought to provide updated technical information at every given opportunity. The 2025 HELAA relating to the landscape impact states that the “Site is highly sensitive in landscape terms and development in this location would be highly visible, creating adverse impacts on landscape character and local views. These impacts are significant when considered cumulatively alongside other development on adjacent land”. It is not clear on what basis this conclusion was reached, as detailed Landscape and Visual Impact Assessments have concluded that development of the site can be sufficiently mitigated through a considerate, landscape-led design and planting scheme.

The July 2026 Sustainability Appraisal Appendix E (Justification for selecting the spatial strategy and site allocations for the plan) states the reason for not proposing the site for allocation as follows:
“The landscape assessment has been changed from Red to Amber. However, the site sits on a slightly more elevated parcel of land compared to its surroundings, which will result in development being more visible. The required landscape mitigation would reduce the capacity of the site. There are a number of sites recently developed or committed on the edge of Linton. There are other sites considered more appropriate for allocation.”

It is considered to be significant that this response does not challenge the sustainability of the site. Further, Endurance Estates contend that the capacity of the site is demonstrated through the supporting plans and application materials which were submitted to Greater Cambridge Planning in support of the Outline Planning Application (Ref: 26/00415/OUT) for the Site in February 2026. Following submission of the Outline Planning Application, it is demonstrated that there are no significant or insurmountable constraints which should preclude development of the site.

As a Minor Rural Centre, Linton is demonstrably a sustainable settlement. Linton benefits from an Infant, Junior and Secondary Schools, a Library, several shops and cafes, public houses, a GP Surgery, dental practice, and an excellent range of sports and recreation facilities, including a skate park, swimming pool and sports pavilion. It is therefore considered that the site, and by extension the village of Linton, benefits from sufficient accessibility to essential shops and services, alongside the ability to travel sustainably further afield for a full array of services in both the surrounding villages and Cambridge.

Linton also now benefits from The Linton Greenway, which is now significantly advanced, providing a quality active travel route between Linton and the Abingtons (including Granta Park) and the planned CSET2 Busway scheme, which will provide fast and direct public transport connections into Cambridge and the Biomedical Campus from a new Travel Hub on the A11 Junction at Fourwentways. The Secretary of State has confirmed the CSET Busway is expected to commence Inquiry in October 2026. Both schemes will materially improve the sustainability of the settlement in a way which we consider has not been reflected in the assessment of the village’s potential to accommodate growth sustainably.
It is expected that subject to approval, the CSET scheme will come forward as envisaged prior to or in a similar timeframe to the development of the site.

The supporting text to Policy S/DS: Development Strategy outlines that “We [Greater Cambridge] also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion”. This acknowledgement is endorsed by Endurance Estates as recognition of the sustainability of villages in the Southern Cluster, which includes Linton. Despite this sensible admission, it makes the lack of any residential allocations within Linton difficult to understand, particularly with the transport enhancement schemes being brought forward by GCP with the express purpose of improving the accessibility of the Village to employment sites.

Endurance Estates contend that the omission of Land South of Horseheath Road fails to recognise Linton’s accessible location and the likelihood that this will shortly be enhanced through planned public transport improvements, along with the good level of existing service provision. The site and village as a whole is outside of the Green Belt and the identified landscape constraints are capable of being overcome through a landscape-led design approach

Linton is therefore demonstrably a sustainable location capable for accommodating further housing growth to meet the identified local need and its allocation would be consistent with the strategy of focussing growth in the Rural Southern Cluster, close to existing employment sites. In this regard, Greater Cambridge should allocate Land South of Horseheath Road for a sustainable development of approximately 100 market and affordable homes within the village.

The Site remains Available, Achievable and Suitable for residential development.

Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)

Endurance Estates objects strongly to the proposed Inset Map for Balsham on the grounds that it does not propose allocation of Land at Old House Road for residential development. The Policies Map proposes no residential allocations within the village, Endurance Estates are promoting Land to the Rear of Old House Road, Balsham which is considered capable of accommodating a scheme of approximately 25 new dwellings.

Crucially, draft Policy S/SH states that “limited development will help maintain remaining services and facilities and provide for affordable housing to meet local needs”. This acknowledgement is strongly supported by Endurance Estates, however the lack of any allocated development to ensure the long-term vitality of the village’s facilities is disappointing.

Balsham had a population of 1,623 as of the 2021 Census, which represents an approximate 1% decrease on the 1,641 residents recorded at the 2001 Census. This contrasts starkly with the wider South Cambridgeshire district, which grew by just under 25% in the same time period. This stagnation places the village’s existing services at risk of further decline. As correctly identified by the supporting text to Policy S/SH, additional growth in villages such as Balsham is key to maintaining their vitality. Simply, without growth, the range of shops and essential services is likely to continue to deteriorate.

In terms Land to the Rear of Old House Road, there were no significant issues which cannot be mitigated through the scheme design which were raised in the 2021, 2023 or 2025 HELAA documents.
Endurance Estates contend that the Inset Map for Balsham should be urgently updated to ensure that controlled growth can come forward, in support of essential services through the allocation of sites such as Land to the Rear of Old House Road.

The Site remains Available, Achievable and Suitable for residential development.





Land off the Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
Land off Elbourn Way, Bassingbourn (Site ID 116006, HELAA ID 40227).
Endurance Estates objects strongly to the proposed Inset Map for Bassingbourn on the grounds that it does not propose allocation of either Land off the Causeway, or Land off Elbourn Way for residential development. The Policies Map proposes no residential allocations within the village, despite it being a sustainable Minor Rural Centre. Greater Cambridge recognises that the village plays a role in providing services and facilities for a rural hinterland; however, the lack of allocations to secure controlled growth moving forward puts existing services at risk of decline.

Bassingbourn had a population of 2,351 at the 2021 Census which represents a marked decrease on the 3,090 residents that lived in the village at the time of the 2001 Census. This decline is in stark contrast with South Cambridgeshire, which grew by just under 25% in the same time period. There is therefore an urgent need to protect the vitality of the village to secure the ongoing provision of shops, services and community facilities. The Village currently hosts a good range of shops and services including a Spar Convenience Store, Public Houses and a community centre. The Village also benefits from Bassingbourn Primary and Bassingbourn Village College. Without additional growth in villages such as Bassingbourn, which play key roles in the delivery of shops and services for rural areas of South Cambridgeshire, the breadth and quality of key shops and services is likely to deteriorate, ultimately harming the sustainability of the settlement in the long term.

The Inset Map for Bassingbourn should be updated to reflect the role of the village as a Minor Rural Centre. Proportional and sympathetic extensions to the village, such as those proposed at Land off the Causeway and Land off Elbourn Way, are the best and most effective way to securing the continued viability of essential services and facilities and maintaining the vitality of the village in accordance with paragraph 83 of the NPPF.

The Site remains Available, Achievable and Suitable for residential development.

Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)
Endurance Estates objects strongly to the proposed Inset Map for Orwell on the basis of the omission of a site specific policy allocating Land at Hillside, Orwell for a residential development.

Orwell is categorised as a Group Village under draft Policy S/SH. The village has experienced moderate growth since the 2001 Census, increasing by approximately 6%. However, this is significantly below the growth rate of South Cambridgeshire, which saw population growth of just under 25% during the same period. As of the 2025 Regulation 18 Consultation, there are no residential allocations proposed within the village.

Orwell benefits from a Primary School, Public House, Post Office, Convenience Store and a Village Hall. The Village also has a good bus connection to Cambridge for a wider range of services.

Land at Hillside, Orwell, is promoted by Endurance Estates for a landscape-led development of approximately 26 dwellings. The 2025 HELAA did not assess the site as it was deemed to “not align with the wider Local Plan Strategy”. Endurance Estates consider that this fails to consider the contribution that the Site could make towards a controlled and proportionate growth of the Village in order to support essential services and facilities to maintain the vitality of the village in accordance with paragraph 85 of the NPPF.

Since the development at Hurdleditch Road was approved in 2016 (S/3190/15/OL), no further major schemes have been approved in the village. Partly as a result of the lack of site allocations there within the Adopted Local Plan.

Department of Education records indicate that the Petersfield C of E Primary School has 134 pupils on roll and a capacity of 210, indicating that the school is currently operating at around 64% capacity. This suggests there is capacity for growth within the village, which would help safeguard existing services for the benefit of current and future residents.
The Inset Map for Orwell should be updated to reflect the capacity of the village for a controlled and proportionate level of growth to support the Village’s services. This should include, as a minimum, Land at Hillside, Orwell for a residential development of circa 26 dwellings.
The Site remains Available, Achievable and Suitable for residential development.
Conclusions

Accordingly, for the reasons outlined above, Endurance Estates contends that Policy S/RRA is unsound. By focusing growth almost exclusively on strategic sites and constraining the range and distribution of housing growth by largely excluding growth at sustainable villages, the Plan risks:
• Failing to meet local market and affordable housing needs.
• Increasing commuting and associated congestion and emissions.
• Undermining the vitality and viability of village services and facilities.
• Over-reliance on a small number of large allocations, reducing delivery resilience.
• Failing to capitalise on committed transport investments, including: GCP Greenways and the CSET Busway Mass-rapid transit scheme;.
• Exacerbating affordability pressures and undermining the labour supply and economic growth ambitions of Greater Cambridge.

Accordingly, the policy is not positively prepared, justified, effective or consistent with national policy.

The allocation of a small number of additional, smaller and more easily deliverable sites in the Rest of the Rural Area, such as Endurance Estates sites listed above, would go some way to meeting this need, whilst also strengthening the Council’s slim 5-year housing land housing supply buffer, which by the Council’s own admission, is marginal upon adoption of the Plan.

The proposed housing in the ‘Rest of the Rural Area’ should be increased to meet the National Requirements as set out in HO6 – namely, to allocate specific sites to meet at least 10% of the housing requirement; a further 10% for medium sites (up to 2.5ha) along with other proportionate allocations to meet local needs with sufficient sites to support the village economies, local services and facilities.

Draft Policy S/RRA allocates specific sites within the rest of the Rural Area to help meet the development needs across Greater Cambridge. Endurance Estates, objects to the draft Policy on the basis that the housing allocations identified within the Rest of the Rural Area are insufficient to meet local housing needs in villages, and further, that it omits Endurances sites for residential development. The Policy is therefore not considered to be positively prepared, justified, effective or consistent with national policy and is unsound.

Endurance Estates consider that the housing allocations proposed in the Regulation 19 Proposed Submission Local Plan across the rural area are insufficient to meet local housing needs in the villages of the District The lack of new housing site allocations in the villages within the Rural Area reflect wider concerns set out in our responses to other Policies (S/JH and S/DS) that confirm the Plan is not providing for sufficient number of new homes in the right places.

In addition to the inherent spatial imbalance which exists due to the lack of significant allocations south and east of the City, the Development Strategy being pursued, has resulted in very few new housing allocations in the ‘Rest of the Rural Area’, which are largely overlooked in favour of significant New-Settlement allocations.

Endurance Estates are also concerned that the Plan does not appear to meet the requirements of Part (a) of Policy HO6 of the NPPF 2026 which requires the Council to allocate 10% of their housing requirement on sites no larger than 1 hectare, and a further 10% between 1-and-2.5 hectares.

Further, the Part (b) of Policy HO6 requires the Councils to 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”. The Government’s intention is therefore clear - growth within villages is essential to ensure they continue to be vibrant, inclusive communities with new opportunities for residents to stay in those communities. Such sites are necessary as part of a blended, robust housing land supply to meet needs across the whole of Greater Cambridge, and to deliver a spatial development strategy that is positively prepared, justified, effective and consistent with national policy.

The Regulation 19 Plan makes only a handful of allocations within the ‘Rest of the Rural Area’.

• S/RRA/ML (Moor Lane) – 20 dwellings
• S/RRA/H (Highfields Phase 2) – 65 dwellings
• S/RRA/ (Cambridge Road, Melbourn) – 125 dwellings
• S/AMC/FD (Land Settlement Association Estate Area of Major Change) – No clear use
• S/AMC/HIS (Histon and Impington Station) – Mixed use – no quantum confirmed
As set out above, across the S/RRA Policies, there are only very limited allocations for residential development, with most being for employment, or unspecified mixed uses. The residential allocations are confined to Moor Lane, Highfields and Melbourn, totalling just 210 homes across the District - equal less than 0.5% of the identified housing requirement. Endurance considers this to be woefully insufficient to meet the needs of the villages of the district and does nothing to support the local economies and services within these settlements.

It is considered that the housing allocations identified within the Rest of the Rural Area are not aligned with the settlement hierarchy in terms of distribution and scale of development.

As mentioned within our representations to Policy S/DS, there is a strong focus within the Draft Local Plan on the delivery of strategic sites, particularly New Settlements. Whilst it is recognised that strategic sites are capable of delivering large numbers of homes and making a meaningful contribution to meeting identified development needs, the proposed New Settlements make up almost half of the planned housing supply. This reliance on large strategic sites places an undue reliance and significant dependence on such sites and risks under delivery in the face of any delays to their delivery, particularly as many of these sites are subject to significant infrastructure delivery requirements.

Over-reliance on Windfall

Paragraph 2.41 of the Regulation 19 Plan confirms that the Councils intend to rely heavily upon windfall to meet the small-sites requirement. The Councils contend that allocating the full amount on specific identified sites would be “extremely challenging”. Endurance Estates contend that this is not a sound strategy and Policy HO6 is clear that the Councils should be allocating specific sites to meet this need. Allocation of a small number of additional sites in the Rest of the Rural Area, such as Endurance Estates’ sites below, would go some way to meeting this need.

The arguments for not allocating specific sites, such as the highly-sustainable Endurance Estates sites outlined below, in is not justified. The Councils state that allocation of the full small-sites requirement would direct “a significant portion of growth to less sustainable locations where levels of car use would be higher, negatively impacting our response to the challenges of net zero carbon and Climate Act obligations and undermining our vision and strategic priorities”. Notwithstanding this, the reliance upon windfall to meet this need appears to be in conflict with this statement.

The Policy as currently drafted risks artificially constraining housing provision outside of Cambridge and the New Settlement allocations. In doing so, the Plan risks worsening affordability pressures, already present within the District, whilst increasing the need to commute and restricting labour supply. Ultimately, in failing to deliver sufficient new homes in the villages of the District – in addition to those in Cambridge and the new settlements – the Council are constraining business and economic growth. This is at odds with the stated ambitions of the Government, and the Councils’ own evidence and as such will fail to support the planned economic growth of the City region.

In relying upon windfall developments to exclusively meet the housing needs of the majority of the villages of the District, and when considered in combination with S/SH - which Endurance have also made representations on within this submission – the Council are restricting the ability of developments to meet the affordable needs of the villages. Policy S/SH currently restricts Local Service Centres to “an indicative maximum scheme size of 30 dwellings” and Group Villages to “an indicative maximum scheme size of 8 dwellings” with up to 15 in ‘exceptional’ circumstances. As mandatory Affordable Housing provision is only triggered on Major sites, the Council are relying exclusively on goodwill and rural exceptions sites. This is not considered a robust approach to meeting the affordable housing needs of the District’s villages.

Meeting Local Housing Needs

The evidence base does not assess affordable housing need within the District's villages, which raises the question of whether the Plan and Policies can be said to address local housing needs and whether they have been properly planned for.
The Plan itself acknowledges that locating homes closer to employment can reduce commuting. Sustainable villages, including those benefiting from committed transport improvements, can make a meaningful contribution to this objective. The absence of significant housing allocations in such locations therefore represents a missed opportunity to support sustainable travel patterns.
The proposed housing strategy also lacks sufficient diversity. Only a small proportion of housing need is expected to be delivered through specific small and medium-sized allocations, with significant reliance on windfalls and large strategic sites. This approach is inconsistent with the Government's increasing emphasis on the role of small and medium-sized sites in boosting housing delivery and market diversity. Evidence consistently shows that smaller sites are delivered more quickly and can improve resilience within the housing trajectory.
The Plan should therefore identify additional small and medium-sized allocations in suitable village locations and ensure new settlements are supported by sufficient employment opportunities to create balanced and sustainable communities.

In particular, Endurance Estates strongly objects to Draft Policy S/RRA on the basis that it omits the following proposed site allocations:

• 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)
These sites are considered in turn below.
Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
Endurance Estates have consistently promoted Land South of Horseheath Road and sought to provide updated technical information at every given opportunity. The 2025 HELAA relating to the landscape impact states that the “Site is highly sensitive in landscape terms and development in this location would be highly visible, creating adverse impacts on landscape character and local views. These impacts are significant when considered cumulatively alongside other development on adjacent land”. It is not clear on what basis this conclusion was reached, as detailed Landscape and Visual Impact Assessments have concluded that development of the site can be sufficiently mitigated through a considerate, landscape-led design and planting scheme.

The July 2026 Sustainability Appraisal Appendix E (Justification for selecting the spatial strategy and site allocations for the plan) states the reason for not proposing the site for allocation as follows:
“The landscape assessment has been changed from Red to Amber. However, the site sits on a slightly more elevated parcel of land compared to its surroundings, which will result in development being more visible. The required landscape mitigation would reduce the capacity of the site. There are a number of sites recently developed or committed on the edge of Linton. There are other sites considered more appropriate for allocation.”

It is considered to be significant that this response does not challenge the sustainability of the site. Further, Endurance Estates contend that the capacity of the site is demonstrated through the supporting plans and application materials which were submitted to Greater Cambridge Planning in support of the Outline Planning Application (Ref: 26/00415/OUT) for the Site in February 2026. Following submission of the Outline Planning Application, it is demonstrated that there are no significant or insurmountable constraints which should preclude development of the site.

As a Minor Rural Centre, Linton is demonstrably a sustainable settlement. Linton benefits from an Infant, Junior and Secondary Schools, a Library, several shops and cafes, public houses, a GP Surgery, dental practice, and an excellent range of sports and recreation facilities, including a skate park, swimming pool and sports pavilion. It is therefore considered that the site, and by extension the village of Linton, benefits from sufficient accessibility to essential shops and services, alongside the ability to travel sustainably further afield for a full array of services in both the surrounding villages and Cambridge.

Linton also now benefits from The Linton Greenway, which is now significantly advanced, providing a quality active travel route between Linton and the Abingtons (including Granta Park) and the planned CSET2 Busway scheme, which will provide fast and direct public transport connections into Cambridge and the Biomedical Campus from a new Travel Hub on the A11 Junction at Fourwentways. The Secretary of State has confirmed the CSET Busway is expected to commence Inquiry in October 2026. Both schemes will materially improve the sustainability of the settlement in a way which we consider has not been reflected in the assessment of the village’s potential to accommodate growth sustainably.
It is expected that subject to approval, the CSET scheme will come forward as envisaged prior to or in a similar timeframe to the development of the site.

The supporting text to Policy S/DS: Development Strategy outlines that “We [Greater Cambridge] also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion”. This acknowledgement is endorsed by Endurance Estates as recognition of the sustainability of villages in the Southern Cluster, which includes Linton. Despite this sensible admission, it makes the lack of any residential allocations within Linton difficult to understand, particularly with the transport enhancement schemes being brought forward by GCP with the express purpose of improving the accessibility of the Village to employment sites.

Endurance Estates contend that the omission of Land South of Horseheath Road fails to recognise Linton’s accessible location and the likelihood that this will shortly be enhanced through planned public transport improvements, along with the good level of existing service provision. The site and village as a whole is outside of the Green Belt and the identified landscape constraints are capable of being overcome through a landscape-led design approach

Linton is therefore demonstrably a sustainable location capable for accommodating further housing growth to meet the identified local need and its allocation would be consistent with the strategy of focussing growth in the Rural Southern Cluster, close to existing employment sites. In this regard, Greater Cambridge should allocate Land South of Horseheath Road for a sustainable development of approximately 100 market and affordable homes within the village.

The Site remains Available, Achievable and Suitable for residential development.

Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)

Endurance Estates objects strongly to the proposed Inset Map for Balsham on the grounds that it does not propose allocation of Land at Old House Road for residential development. The Policies Map proposes no residential allocations within the village, Endurance Estates are promoting Land to the Rear of Old House Road, Balsham which is considered capable of accommodating a scheme of approximately 25 new dwellings.

Crucially, draft Policy S/SH states that “limited development will help maintain remaining services and facilities and provide for affordable housing to meet local needs”. This acknowledgement is strongly supported by Endurance Estates, however the lack of any allocated development to ensure the long-term vitality of the village’s facilities is disappointing.

Balsham had a population of 1,623 as of the 2021 Census, which represents an approximate 1% decrease on the 1,641 residents recorded at the 2001 Census. This contrasts starkly with the wider South Cambridgeshire district, which grew by just under 25% in the same time period. This stagnation places the village’s existing services at risk of further decline. As correctly identified by the supporting text to Policy S/SH, additional growth in villages such as Balsham is key to maintaining their vitality. Simply, without growth, the range of shops and essential services is likely to continue to deteriorate.

In terms Land to the Rear of Old House Road, there were no significant issues which cannot be mitigated through the scheme design which were raised in the 2021, 2023 or 2025 HELAA documents.
Endurance Estates contend that the Inset Map for Balsham should be urgently updated to ensure that controlled growth can come forward, in support of essential services through the allocation of sites such as Land to the Rear of Old House Road.

The Site remains Available, Achievable and Suitable for residential development.





Land off the Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
Land off Elbourn Way, Bassingbourn (Site ID 116006, HELAA ID 40227).
Endurance Estates objects strongly to the proposed Inset Map for Bassingbourn on the grounds that it does not propose allocation of either Land off the Causeway, or Land off Elbourn Way for residential development. The Policies Map proposes no residential allocations within the village, despite it being a sustainable Minor Rural Centre. Greater Cambridge recognises that the village plays a role in providing services and facilities for a rural hinterland; however, the lack of allocations to secure controlled growth moving forward puts existing services at risk of decline.

Bassingbourn had a population of 2,351 at the 2021 Census which represents a marked decrease on the 3,090 residents that lived in the village at the time of the 2001 Census. This decline is in stark contrast with South Cambridgeshire, which grew by just under 25% in the same time period. There is therefore an urgent need to protect the vitality of the village to secure the ongoing provision of shops, services and community facilities. The Village currently hosts a good range of shops and services including a Spar Convenience Store, Public Houses and a community centre. The Village also benefits from Bassingbourn Primary and Bassingbourn Village College. Without additional growth in villages such as Bassingbourn, which play key roles in the delivery of shops and services for rural areas of South Cambridgeshire, the breadth and quality of key shops and services is likely to deteriorate, ultimately harming the sustainability of the settlement in the long term.

The Inset Map for Bassingbourn should be updated to reflect the role of the village as a Minor Rural Centre. Proportional and sympathetic extensions to the village, such as those proposed at Land off the Causeway and Land off Elbourn Way, are the best and most effective way to securing the continued viability of essential services and facilities and maintaining the vitality of the village in accordance with paragraph 83 of the NPPF.

The Site remains Available, Achievable and Suitable for residential development.

Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)
Endurance Estates objects strongly to the proposed Inset Map for Orwell on the basis of the omission of a site specific policy allocating Land at Hillside, Orwell for a residential development.

Orwell is categorised as a Group Village under draft Policy S/SH. The village has experienced moderate growth since the 2001 Census, increasing by approximately 6%. However, this is significantly below the growth rate of South Cambridgeshire, which saw population growth of just under 25% during the same period. As of the 2025 Regulation 18 Consultation, there are no residential allocations proposed within the village.

Orwell benefits from a Primary School, Public House, Post Office, Convenience Store and a Village Hall. The Village also has a good bus connection to Cambridge for a wider range of services.

Land at Hillside, Orwell, is promoted by Endurance Estates for a landscape-led development of approximately 26 dwellings. The 2025 HELAA did not assess the site as it was deemed to “not align with the wider Local Plan Strategy”. Endurance Estates consider that this fails to consider the contribution that the Site could make towards a controlled and proportionate growth of the Village in order to support essential services and facilities to maintain the vitality of the village in accordance with paragraph 85 of the NPPF.

Since the development at Hurdleditch Road was approved in 2016 (S/3190/15/OL), no further major schemes have been approved in the village. Partly as a result of the lack of site allocations there within the Adopted Local Plan.

Department of Education records indicate that the Petersfield C of E Primary School has 134 pupils on roll and a capacity of 210, indicating that the school is currently operating at around 64% capacity. This suggests there is capacity for growth within the village, which would help safeguard existing services for the benefit of current and future residents.
The Inset Map for Orwell should be updated to reflect the capacity of the village for a controlled and proportionate level of growth to support the Village’s services. This should include, as a minimum, Land at Hillside, Orwell for a residential development of circa 26 dwellings.
The Site remains Available, Achievable and Suitable for residential development.
Conclusions

Accordingly, for the reasons outlined above, Endurance Estates contends that Policy S/RRA is unsound. By focusing growth almost exclusively on strategic sites and constraining the range and distribution of housing growth by largely excluding growth at sustainable villages, the Plan risks:
• Failing to meet local market and affordable housing needs.
• Increasing commuting and associated congestion and emissions.
• Undermining the vitality and viability of village services and facilities.
• Over-reliance on a small number of large allocations, reducing delivery resilience.
• Failing to capitalise on committed transport investments, including: GCP Greenways and the CSET Busway Mass-rapid transit scheme;.
• Exacerbating affordability pressures and undermining the labour supply and economic growth ambitions of Greater Cambridge.

Accordingly, the policy is not positively prepared, justified, effective or consistent with national policy.

The allocation of a small number of additional, smaller and more easily deliverable sites in the Rest of the Rural Area, such as Endurance Estates sites listed above, would go some way to meeting this need, whilst also strengthening the Council’s slim 5-year housing land housing supply buffer, which by the Council’s own admission, is marginal upon adoption of the Plan.

The proposed housing in the ‘Rest of the Rural Area’ should be increased to meet the National Requirements as set out in HO6 – namely, to allocate specific sites to meet at least 10% of the housing requirement; a further 10% for medium sites (up to 2.5ha) along with other proportionate allocations to meet local needs with sufficient sites to support the village economies, local services and facilities.

Draft Policy S/RRA allocates specific sites within the rest of the Rural Area to help meet the development needs across Greater Cambridge. Endurance Estates, objects to the draft Policy on the basis that the housing allocations identified within the Rest of the Rural Area are insufficient to meet local housing needs in villages, and further, that it omits Endurances sites for residential development. The Policy is therefore not considered to be positively prepared, justified, effective or consistent with national policy and is unsound.

Endurance Estates consider that the housing allocations proposed in the Regulation 19 Proposed Submission Local Plan across the rural area are insufficient to meet local housing needs in the villages of the District The lack of new housing site allocations in the villages within the Rural Area reflect wider concerns set out in our responses to other Policies (S/JH and S/DS) that confirm the Plan is not providing for sufficient number of new homes in the right places.

In addition to the inherent spatial imbalance which exists due to the lack of significant allocations south and east of the City, the Development Strategy being pursued, has resulted in very few new housing allocations in the ‘Rest of the Rural Area’, which are largely overlooked in favour of significant New-Settlement allocations.

Endurance Estates are also concerned that the Plan does not appear to meet the requirements of Part (a) of Policy HO6 of the NPPF 2026 which requires the Council to allocate 10% of their housing requirement on sites no larger than 1 hectare, and a further 10% between 1-and-2.5 hectares.

Further, the Part (b) of Policy HO6 requires the Councils to 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”. The Government’s intention is therefore clear - growth within villages is essential to ensure they continue to be vibrant, inclusive communities with new opportunities for residents to stay in those communities. Such sites are necessary as part of a blended, robust housing land supply to meet needs across the whole of Greater Cambridge, and to deliver a spatial development strategy that is positively prepared, justified, effective and consistent with national policy.

The Regulation 19 Plan makes only a handful of allocations within the ‘Rest of the Rural Area’.

• S/RRA/ML (Moor Lane) – 20 dwellings
• S/RRA/H (Highfields Phase 2) – 65 dwellings
• S/RRA/ (Cambridge Road, Melbourn) – 125 dwellings
• S/AMC/FD (Land Settlement Association Estate Area of Major Change) – No clear use
• S/AMC/HIS (Histon and Impington Station) – Mixed use – no quantum confirmed
As set out above, across the S/RRA Policies, there are only very limited allocations for residential development, with most being for employment, or unspecified mixed uses. The residential allocations are confined to Moor Lane, Highfields and Melbourn, totalling just 210 homes across the District - equal less than 0.5% of the identified housing requirement. Endurance considers this to be woefully insufficient to meet the needs of the villages of the district and does nothing to support the local economies and services within these settlements.

It is considered that the housing allocations identified within the Rest of the Rural Area are not aligned with the settlement hierarchy in terms of distribution and scale of development.

As mentioned within our representations to Policy S/DS, there is a strong focus within the Draft Local Plan on the delivery of strategic sites, particularly New Settlements. Whilst it is recognised that strategic sites are capable of delivering large numbers of homes and making a meaningful contribution to meeting identified development needs, the proposed New Settlements make up almost half of the planned housing supply. This reliance on large strategic sites places an undue reliance and significant dependence on such sites and risks under delivery in the face of any delays to their delivery, particularly as many of these sites are subject to significant infrastructure delivery requirements.

Over-reliance on Windfall

Paragraph 2.41 of the Regulation 19 Plan confirms that the Councils intend to rely heavily upon windfall to meet the small-sites requirement. The Councils contend that allocating the full amount on specific identified sites would be “extremely challenging”. Endurance Estates contend that this is not a sound strategy and Policy HO6 is clear that the Councils should be allocating specific sites to meet this need. Allocation of a small number of additional sites in the Rest of the Rural Area, such as Endurance Estates’ sites below, would go some way to meeting this need.

The arguments for not allocating specific sites, such as the highly-sustainable Endurance Estates sites outlined below, in is not justified. The Councils state that allocation of the full small-sites requirement would direct “a significant portion of growth to less sustainable locations where levels of car use would be higher, negatively impacting our response to the challenges of net zero carbon and Climate Act obligations and undermining our vision and strategic priorities”. Notwithstanding this, the reliance upon windfall to meet this need appears to be in conflict with this statement.

The Policy as currently drafted risks artificially constraining housing provision outside of Cambridge and the New Settlement allocations. In doing so, the Plan risks worsening affordability pressures, already present within the District, whilst increasing the need to commute and restricting labour supply. Ultimately, in failing to deliver sufficient new homes in the villages of the District – in addition to those in Cambridge and the new settlements – the Council are constraining business and economic growth. This is at odds with the stated ambitions of the Government, and the Councils’ own evidence and as such will fail to support the planned economic growth of the City region.

In relying upon windfall developments to exclusively meet the housing needs of the majority of the villages of the District, and when considered in combination with S/SH - which Endurance have also made representations on within this submission – the Council are restricting the ability of developments to meet the affordable needs of the villages. Policy S/SH currently restricts Local Service Centres to “an indicative maximum scheme size of 30 dwellings” and Group Villages to “an indicative maximum scheme size of 8 dwellings” with up to 15 in ‘exceptional’ circumstances. As mandatory Affordable Housing provision is only triggered on Major sites, the Council are relying exclusively on goodwill and rural exceptions sites. This is not considered a robust approach to meeting the affordable housing needs of the District’s villages.

Meeting Local Housing Needs

The evidence base does not assess affordable housing need within the District's villages, which raises the question of whether the Plan and Policies can be said to address local housing needs and whether they have been properly planned for.
The Plan itself acknowledges that locating homes closer to employment can reduce commuting. Sustainable villages, including those benefiting from committed transport improvements, can make a meaningful contribution to this objective. The absence of significant housing allocations in such locations therefore represents a missed opportunity to support sustainable travel patterns.
The proposed housing strategy also lacks sufficient diversity. Only a small proportion of housing need is expected to be delivered through specific small and medium-sized allocations, with significant reliance on windfalls and large strategic sites. This approach is inconsistent with the Government's increasing emphasis on the role of small and medium-sized sites in boosting housing delivery and market diversity. Evidence consistently shows that smaller sites are delivered more quickly and can improve resilience within the housing trajectory.
The Plan should therefore identify additional small and medium-sized allocations in suitable village locations and ensure new settlements are supported by sufficient employment opportunities to create balanced and sustainable communities.

In particular, Endurance Estates strongly objects to Draft Policy S/RRA on the basis that it omits the following proposed site allocations:

• 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)
These sites are considered in turn below.
Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
Endurance Estates have consistently promoted Land South of Horseheath Road and sought to provide updated technical information at every given opportunity. The 2025 HELAA relating to the landscape impact states that the “Site is highly sensitive in landscape terms and development in this location would be highly visible, creating adverse impacts on landscape character and local views. These impacts are significant when considered cumulatively alongside other development on adjacent land”. It is not clear on what basis this conclusion was reached, as detailed Landscape and Visual Impact Assessments have concluded that development of the site can be sufficiently mitigated through a considerate, landscape-led design and planting scheme.

The July 2026 Sustainability Appraisal Appendix E (Justification for selecting the spatial strategy and site allocations for the plan) states the reason for not proposing the site for allocation as follows:
“The landscape assessment has been changed from Red to Amber. However, the site sits on a slightly more elevated parcel of land compared to its surroundings, which will result in development being more visible. The required landscape mitigation would reduce the capacity of the site. There are a number of sites recently developed or committed on the edge of Linton. There are other sites considered more appropriate for allocation.”

It is considered to be significant that this response does not challenge the sustainability of the site. Further, Endurance Estates contend that the capacity of the site is demonstrated through the supporting plans and application materials which were submitted to Greater Cambridge Planning in support of the Outline Planning Application (Ref: 26/00415/OUT) for the Site in February 2026. Following submission of the Outline Planning Application, it is demonstrated that there are no significant or insurmountable constraints which should preclude development of the site.

As a Minor Rural Centre, Linton is demonstrably a sustainable settlement. Linton benefits from an Infant, Junior and Secondary Schools, a Library, several shops and cafes, public houses, a GP Surgery, dental practice, and an excellent range of sports and recreation facilities, including a skate park, swimming pool and sports pavilion. It is therefore considered that the site, and by extension the village of Linton, benefits from sufficient accessibility to essential shops and services, alongside the ability to travel sustainably further afield for a full array of services in both the surrounding villages and Cambridge.

Linton also now benefits from The Linton Greenway, which is now significantly advanced, providing a quality active travel route between Linton and the Abingtons (including Granta Park) and the planned CSET2 Busway scheme, which will provide fast and direct public transport connections into Cambridge and the Biomedical Campus from a new Travel Hub on the A11 Junction at Fourwentways. The Secretary of State has confirmed the CSET Busway is expected to commence Inquiry in October 2026. Both schemes will materially improve the sustainability of the settlement in a way which we consider has not been reflected in the assessment of the village’s potential to accommodate growth sustainably.
It is expected that subject to approval, the CSET scheme will come forward as envisaged prior to or in a similar timeframe to the development of the site.

The supporting text to Policy S/DS: Development Strategy outlines that “We [Greater Cambridge] also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion”. This acknowledgement is endorsed by Endurance Estates as recognition of the sustainability of villages in the Southern Cluster, which includes Linton. Despite this sensible admission, it makes the lack of any residential allocations within Linton difficult to understand, particularly with the transport enhancement schemes being brought forward by GCP with the express purpose of improving the accessibility of the Village to employment sites.

Endurance Estates contend that the omission of Land South of Horseheath Road fails to recognise Linton’s accessible location and the likelihood that this will shortly be enhanced through planned public transport improvements, along with the good level of existing service provision. The site and village as a whole is outside of the Green Belt and the identified landscape constraints are capable of being overcome through a landscape-led design approach

Linton is therefore demonstrably a sustainable location capable for accommodating further housing growth to meet the identified local need and its allocation would be consistent with the strategy of focussing growth in the Rural Southern Cluster, close to existing employment sites. In this regard, Greater Cambridge should allocate Land South of Horseheath Road for a sustainable development of approximately 100 market and affordable homes within the village.

The Site remains Available, Achievable and Suitable for residential development.

Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)

Endurance Estates objects strongly to the proposed Inset Map for Balsham on the grounds that it does not propose allocation of Land at Old House Road for residential development. The Policies Map proposes no residential allocations within the village, Endurance Estates are promoting Land to the Rear of Old House Road, Balsham which is considered capable of accommodating a scheme of approximately 25 new dwellings.

Crucially, draft Policy S/SH states that “limited development will help maintain remaining services and facilities and provide for affordable housing to meet local needs”. This acknowledgement is strongly supported by Endurance Estates, however the lack of any allocated development to ensure the long-term vitality of the village’s facilities is disappointing.

Balsham had a population of 1,623 as of the 2021 Census, which represents an approximate 1% decrease on the 1,641 residents recorded at the 2001 Census. This contrasts starkly with the wider South Cambridgeshire district, which grew by just under 25% in the same time period. This stagnation places the village’s existing services at risk of further decline. As correctly identified by the supporting text to Policy S/SH, additional growth in villages such as Balsham is key to maintaining their vitality. Simply, without growth, the range of shops and essential services is likely to continue to deteriorate.

In terms Land to the Rear of Old House Road, there were no significant issues which cannot be mitigated through the scheme design which were raised in the 2021, 2023 or 2025 HELAA documents.
Endurance Estates contend that the Inset Map for Balsham should be urgently updated to ensure that controlled growth can come forward, in support of essential services through the allocation of sites such as Land to the Rear of Old House Road.

The Site remains Available, Achievable and Suitable for residential development.





Land off the Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
Land off Elbourn Way, Bassingbourn (Site ID 116006, HELAA ID 40227).
Endurance Estates objects strongly to the proposed Inset Map for Bassingbourn on the grounds that it does not propose allocation of either Land off the Causeway, or Land off Elbourn Way for residential development. The Policies Map proposes no residential allocations within the village, despite it being a sustainable Minor Rural Centre. Greater Cambridge recognises that the village plays a role in providing services and facilities for a rural hinterland; however, the lack of allocations to secure controlled growth moving forward puts existing services at risk of decline.

Bassingbourn had a population of 2,351 at the 2021 Census which represents a marked decrease on the 3,090 residents that lived in the village at the time of the 2001 Census. This decline is in stark contrast with South Cambridgeshire, which grew by just under 25% in the same time period. There is therefore an urgent need to protect the vitality of the village to secure the ongoing provision of shops, services and community facilities. The Village currently hosts a good range of shops and services including a Spar Convenience Store, Public Houses and a community centre. The Village also benefits from Bassingbourn Primary and Bassingbourn Village College. Without additional growth in villages such as Bassingbourn, which play key roles in the delivery of shops and services for rural areas of South Cambridgeshire, the breadth and quality of key shops and services is likely to deteriorate, ultimately harming the sustainability of the settlement in the long term.

The Inset Map for Bassingbourn should be updated to reflect the role of the village as a Minor Rural Centre. Proportional and sympathetic extensions to the village, such as those proposed at Land off the Causeway and Land off Elbourn Way, are the best and most effective way to securing the continued viability of essential services and facilities and maintaining the vitality of the village in accordance with paragraph 83 of the NPPF.

The Site remains Available, Achievable and Suitable for residential development.

Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)
Endurance Estates objects strongly to the proposed Inset Map for Orwell on the basis of the omission of a site specific policy allocating Land at Hillside, Orwell for a residential development.

Orwell is categorised as a Group Village under draft Policy S/SH. The village has experienced moderate growth since the 2001 Census, increasing by approximately 6%. However, this is significantly below the growth rate of South Cambridgeshire, which saw population growth of just under 25% during the same period. As of the 2025 Regulation 18 Consultation, there are no residential allocations proposed within the village.

Orwell benefits from a Primary School, Public House, Post Office, Convenience Store and a Village Hall. The Village also has a good bus connection to Cambridge for a wider range of services.

Land at Hillside, Orwell, is promoted by Endurance Estates for a landscape-led development of approximately 26 dwellings. The 2025 HELAA did not assess the site as it was deemed to “not align with the wider Local Plan Strategy”. Endurance Estates consider that this fails to consider the contribution that the Site could make towards a controlled and proportionate growth of the Village in order to support essential services and facilities to maintain the vitality of the village in accordance with paragraph 85 of the NPPF.

Since the development at Hurdleditch Road was approved in 2016 (S/3190/15/OL), no further major schemes have been approved in the village. Partly as a result of the lack of site allocations there within the Adopted Local Plan.

Department of Education records indicate that the Petersfield C of E Primary School has 134 pupils on roll and a capacity of 210, indicating that the school is currently operating at around 64% capacity. This suggests there is capacity for growth within the village, which would help safeguard existing services for the benefit of current and future residents.
The Inset Map for Orwell should be updated to reflect the capacity of the village for a controlled and proportionate level of growth to support the Village’s services. This should include, as a minimum, Land at Hillside, Orwell for a residential development of circa 26 dwellings.
The Site remains Available, Achievable and Suitable for residential development.
Conclusions

Accordingly, for the reasons outlined above, Endurance Estates contends that Policy S/RRA is unsound. By focusing growth almost exclusively on strategic sites and constraining the range and distribution of housing growth by largely excluding growth at sustainable villages, the Plan risks:
• Failing to meet local market and affordable housing needs.
• Increasing commuting and associated congestion and emissions.
• Undermining the vitality and viability of village services and facilities.
• Over-reliance on a small number of large allocations, reducing delivery resilience.
• Failing to capitalise on committed transport investments, including: GCP Greenways and the CSET Busway Mass-rapid transit scheme;.
• Exacerbating affordability pressures and undermining the labour supply and economic growth ambitions of Greater Cambridge.

Accordingly, the policy is not positively prepared, justified, effective or consistent with national policy.

The allocation of a small number of additional, smaller and more easily deliverable sites in the Rest of the Rural Area, such as Endurance Estates sites listed above, would go some way to meeting this need, whilst also strengthening the Council’s slim 5-year housing land housing supply buffer, which by the Council’s own admission, is marginal upon adoption of the Plan.

The proposed housing in the ‘Rest of the Rural Area’ should be increased to meet the National Requirements as set out in HO6 – namely, to allocate specific sites to meet at least 10% of the housing requirement; a further 10% for medium sites (up to 2.5ha) along with other proportionate allocations to meet local needs with sufficient sites to support the village economies, local services and facilities.

Draft Policy S/RRA allocates specific sites within the rest of the Rural Area to help meet the development needs across Greater Cambridge. Endurance Estates, objects to the draft Policy on the basis that the housing allocations identified within the Rest of the Rural Area are insufficient to meet local housing needs in villages, and further, that it omits Endurances sites for residential development. The Policy is therefore not considered to be positively prepared, justified, effective or consistent with national policy and is unsound.

Endurance Estates consider that the housing allocations proposed in the Regulation 19 Proposed Submission Local Plan across the rural area are insufficient to meet local housing needs in the villages of the District The lack of new housing site allocations in the villages within the Rural Area reflect wider concerns set out in our responses to other Policies (S/JH and S/DS) that confirm the Plan is not providing for sufficient number of new homes in the right places.

In addition to the inherent spatial imbalance which exists due to the lack of significant allocations south and east of the City, the Development Strategy being pursued, has resulted in very few new housing allocations in the ‘Rest of the Rural Area’, which are largely overlooked in favour of significant New-Settlement allocations.

Endurance Estates are also concerned that the Plan does not appear to meet the requirements of Part (a) of Policy HO6 of the NPPF 2026 which requires the Council to allocate 10% of their housing requirement on sites no larger than 1 hectare, and a further 10% between 1-and-2.5 hectares.

Further, the Part (b) of Policy HO6 requires the Councils to 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”. The Government’s intention is therefore clear - growth within villages is essential to ensure they continue to be vibrant, inclusive communities with new opportunities for residents to stay in those communities. Such sites are necessary as part of a blended, robust housing land supply to meet needs across the whole of Greater Cambridge, and to deliver a spatial development strategy that is positively prepared, justified, effective and consistent with national policy.

The Regulation 19 Plan makes only a handful of allocations within the ‘Rest of the Rural Area’.

• S/RRA/ML (Moor Lane) – 20 dwellings
• S/RRA/H (Highfields Phase 2) – 65 dwellings
• S/RRA/ (Cambridge Road, Melbourn) – 125 dwellings
• S/AMC/FD (Land Settlement Association Estate Area of Major Change) – No clear use
• S/AMC/HIS (Histon and Impington Station) – Mixed use – no quantum confirmed
As set out above, across the S/RRA Policies, there are only very limited allocations for residential development, with most being for employment, or unspecified mixed uses. The residential allocations are confined to Moor Lane, Highfields and Melbourn, totalling just 210 homes across the District - equal less than 0.5% of the identified housing requirement. Endurance considers this to be woefully insufficient to meet the needs of the villages of the district and does nothing to support the local economies and services within these settlements.

It is considered that the housing allocations identified within the Rest of the Rural Area are not aligned with the settlement hierarchy in terms of distribution and scale of development.

As mentioned within our representations to Policy S/DS, there is a strong focus within the Draft Local Plan on the delivery of strategic sites, particularly New Settlements. Whilst it is recognised that strategic sites are capable of delivering large numbers of homes and making a meaningful contribution to meeting identified development needs, the proposed New Settlements make up almost half of the planned housing supply. This reliance on large strategic sites places an undue reliance and significant dependence on such sites and risks under delivery in the face of any delays to their delivery, particularly as many of these sites are subject to significant infrastructure delivery requirements.

Over-reliance on Windfall

Paragraph 2.41 of the Regulation 19 Plan confirms that the Councils intend to rely heavily upon windfall to meet the small-sites requirement. The Councils contend that allocating the full amount on specific identified sites would be “extremely challenging”. Endurance Estates contend that this is not a sound strategy and Policy HO6 is clear that the Councils should be allocating specific sites to meet this need. Allocation of a small number of additional sites in the Rest of the Rural Area, such as Endurance Estates’ sites below, would go some way to meeting this need.

The arguments for not allocating specific sites, such as the highly-sustainable Endurance Estates sites outlined below, in is not justified. The Councils state that allocation of the full small-sites requirement would direct “a significant portion of growth to less sustainable locations where levels of car use would be higher, negatively impacting our response to the challenges of net zero carbon and Climate Act obligations and undermining our vision and strategic priorities”. Notwithstanding this, the reliance upon windfall to meet this need appears to be in conflict with this statement.

The Policy as currently drafted risks artificially constraining housing provision outside of Cambridge and the New Settlement allocations. In doing so, the Plan risks worsening affordability pressures, already present within the District, whilst increasing the need to commute and restricting labour supply. Ultimately, in failing to deliver sufficient new homes in the villages of the District – in addition to those in Cambridge and the new settlements – the Council are constraining business and economic growth. This is at odds with the stated ambitions of the Government, and the Councils’ own evidence and as such will fail to support the planned economic growth of the City region.

In relying upon windfall developments to exclusively meet the housing needs of the majority of the villages of the District, and when considered in combination with S/SH - which Endurance have also made representations on within this submission – the Council are restricting the ability of developments to meet the affordable needs of the villages. Policy S/SH currently restricts Local Service Centres to “an indicative maximum scheme size of 30 dwellings” and Group Villages to “an indicative maximum scheme size of 8 dwellings” with up to 15 in ‘exceptional’ circumstances. As mandatory Affordable Housing provision is only triggered on Major sites, the Council are relying exclusively on goodwill and rural exceptions sites. This is not considered a robust approach to meeting the affordable housing needs of the District’s villages.

Meeting Local Housing Needs

The evidence base does not assess affordable housing need within the District's villages, which raises the question of whether the Plan and Policies can be said to address local housing needs and whether they have been properly planned for.
The Plan itself acknowledges that locating homes closer to employment can reduce commuting. Sustainable villages, including those benefiting from committed transport improvements, can make a meaningful contribution to this objective. The absence of significant housing allocations in such locations therefore represents a missed opportunity to support sustainable travel patterns.
The proposed housing strategy also lacks sufficient diversity. Only a small proportion of housing need is expected to be delivered through specific small and medium-sized allocations, with significant reliance on windfalls and large strategic sites. This approach is inconsistent with the Government's increasing emphasis on the role of small and medium-sized sites in boosting housing delivery and market diversity. Evidence consistently shows that smaller sites are delivered more quickly and can improve resilience within the housing trajectory.
The Plan should therefore identify additional small and medium-sized allocations in suitable village locations and ensure new settlements are supported by sufficient employment opportunities to create balanced and sustainable communities.

In particular, Endurance Estates strongly objects to Draft Policy S/RRA on the basis that it omits the following proposed site allocations:

• 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)
These sites are considered in turn below.
Land South of Horseheath Road, Linton (Site ID 115248, HELAA ID 40554)
Endurance Estates have consistently promoted Land South of Horseheath Road and sought to provide updated technical information at every given opportunity. The 2025 HELAA relating to the landscape impact states that the “Site is highly sensitive in landscape terms and development in this location would be highly visible, creating adverse impacts on landscape character and local views. These impacts are significant when considered cumulatively alongside other development on adjacent land”. It is not clear on what basis this conclusion was reached, as detailed Landscape and Visual Impact Assessments have concluded that development of the site can be sufficiently mitigated through a considerate, landscape-led design and planting scheme.

The July 2026 Sustainability Appraisal Appendix E (Justification for selecting the spatial strategy and site allocations for the plan) states the reason for not proposing the site for allocation as follows:
“The landscape assessment has been changed from Red to Amber. However, the site sits on a slightly more elevated parcel of land compared to its surroundings, which will result in development being more visible. The required landscape mitigation would reduce the capacity of the site. There are a number of sites recently developed or committed on the edge of Linton. There are other sites considered more appropriate for allocation.”

It is considered to be significant that this response does not challenge the sustainability of the site. Further, Endurance Estates contend that the capacity of the site is demonstrated through the supporting plans and application materials which were submitted to Greater Cambridge Planning in support of the Outline Planning Application (Ref: 26/00415/OUT) for the Site in February 2026. Following submission of the Outline Planning Application, it is demonstrated that there are no significant or insurmountable constraints which should preclude development of the site.

As a Minor Rural Centre, Linton is demonstrably a sustainable settlement. Linton benefits from an Infant, Junior and Secondary Schools, a Library, several shops and cafes, public houses, a GP Surgery, dental practice, and an excellent range of sports and recreation facilities, including a skate park, swimming pool and sports pavilion. It is therefore considered that the site, and by extension the village of Linton, benefits from sufficient accessibility to essential shops and services, alongside the ability to travel sustainably further afield for a full array of services in both the surrounding villages and Cambridge.

Linton also now benefits from The Linton Greenway, which is now significantly advanced, providing a quality active travel route between Linton and the Abingtons (including Granta Park) and the planned CSET2 Busway scheme, which will provide fast and direct public transport connections into Cambridge and the Biomedical Campus from a new Travel Hub on the A11 Junction at Fourwentways. The Secretary of State has confirmed the CSET Busway is expected to commence Inquiry in October 2026. Both schemes will materially improve the sustainability of the settlement in a way which we consider has not been reflected in the assessment of the village’s potential to accommodate growth sustainably.
It is expected that subject to approval, the CSET scheme will come forward as envisaged prior to or in a similar timeframe to the development of the site.

The supporting text to Policy S/DS: Development Strategy outlines that “We [Greater Cambridge] also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion”. This acknowledgement is endorsed by Endurance Estates as recognition of the sustainability of villages in the Southern Cluster, which includes Linton. Despite this sensible admission, it makes the lack of any residential allocations within Linton difficult to understand, particularly with the transport enhancement schemes being brought forward by GCP with the express purpose of improving the accessibility of the Village to employment sites.

Endurance Estates contend that the omission of Land South of Horseheath Road fails to recognise Linton’s accessible location and the likelihood that this will shortly be enhanced through planned public transport improvements, along with the good level of existing service provision. The site and village as a whole is outside of the Green Belt and the identified landscape constraints are capable of being overcome through a landscape-led design approach

Linton is therefore demonstrably a sustainable location capable for accommodating further housing growth to meet the identified local need and its allocation would be consistent with the strategy of focussing growth in the Rural Southern Cluster, close to existing employment sites. In this regard, Greater Cambridge should allocate Land South of Horseheath Road for a sustainable development of approximately 100 market and affordable homes within the village.

The Site remains Available, Achievable and Suitable for residential development.

Land to the rear of Old House Road, Balsham (Site ID 115953, HELAA ID 40438)

Endurance Estates objects strongly to the proposed Inset Map for Balsham on the grounds that it does not propose allocation of Land at Old House Road for residential development. The Policies Map proposes no residential allocations within the village, Endurance Estates are promoting Land to the Rear of Old House Road, Balsham which is considered capable of accommodating a scheme of approximately 25 new dwellings.

Crucially, draft Policy S/SH states that “limited development will help maintain remaining services and facilities and provide for affordable housing to meet local needs”. This acknowledgement is strongly supported by Endurance Estates, however the lack of any allocated development to ensure the long-term vitality of the village’s facilities is disappointing.

Balsham had a population of 1,623 as of the 2021 Census, which represents an approximate 1% decrease on the 1,641 residents recorded at the 2001 Census. This contrasts starkly with the wider South Cambridgeshire district, which grew by just under 25% in the same time period. This stagnation places the village’s existing services at risk of further decline. As correctly identified by the supporting text to Policy S/SH, additional growth in villages such as Balsham is key to maintaining their vitality. Simply, without growth, the range of shops and essential services is likely to continue to deteriorate.

In terms Land to the Rear of Old House Road, there were no significant issues which cannot be mitigated through the scheme design which were raised in the 2021, 2023 or 2025 HELAA documents.
Endurance Estates contend that the Inset Map for Balsham should be urgently updated to ensure that controlled growth can come forward, in support of essential services through the allocation of sites such as Land to the Rear of Old House Road.

The Site remains Available, Achievable and Suitable for residential development.





Land off the Causeway, Bassingbourn (Site ID 116001, HELAA ID 40228)
Land off Elbourn Way, Bassingbourn (Site ID 116006, HELAA ID 40227).
Endurance Estates objects strongly to the proposed Inset Map for Bassingbourn on the grounds that it does not propose allocation of either Land off the Causeway, or Land off Elbourn Way for residential development. The Policies Map proposes no residential allocations within the village, despite it being a sustainable Minor Rural Centre. Greater Cambridge recognises that the village plays a role in providing services and facilities for a rural hinterland; however, the lack of allocations to secure controlled growth moving forward puts existing services at risk of decline.

Bassingbourn had a population of 2,351 at the 2021 Census which represents a marked decrease on the 3,090 residents that lived in the village at the time of the 2001 Census. This decline is in stark contrast with South Cambridgeshire, which grew by just under 25% in the same time period. There is therefore an urgent need to protect the vitality of the village to secure the ongoing provision of shops, services and community facilities. The Village currently hosts a good range of shops and services including a Spar Convenience Store, Public Houses and a community centre. The Village also benefits from Bassingbourn Primary and Bassingbourn Village College. Without additional growth in villages such as Bassingbourn, which play key roles in the delivery of shops and services for rural areas of South Cambridgeshire, the breadth and quality of key shops and services is likely to deteriorate, ultimately harming the sustainability of the settlement in the long term.

The Inset Map for Bassingbourn should be updated to reflect the role of the village as a Minor Rural Centre. Proportional and sympathetic extensions to the village, such as those proposed at Land off the Causeway and Land off Elbourn Way, are the best and most effective way to securing the continued viability of essential services and facilities and maintaining the vitality of the village in accordance with paragraph 83 of the NPPF.

The Site remains Available, Achievable and Suitable for residential development.

Land at Hillside, Orwell (Site ID 115802, HELAA ID 40496)
Endurance Estates objects strongly to the proposed Inset Map for Orwell on the basis of the omission of a site specific policy allocating Land at Hillside, Orwell for a residential development.

Orwell is categorised as a Group Village under draft Policy S/SH. The village has experienced moderate growth since the 2001 Census, increasing by approximately 6%. However, this is significantly below the growth rate of South Cambridgeshire, which saw population growth of just under 25% during the same period. As of the 2025 Regulation 18 Consultation, there are no residential allocations proposed within the village.

Orwell benefits from a Primary School, Public House, Post Office, Convenience Store and a Village Hall. The Village also has a good bus connection to Cambridge for a wider range of services.

Land at Hillside, Orwell, is promoted by Endurance Estates for a landscape-led development of approximately 26 dwellings. The 2025 HELAA did not assess the site as it was deemed to “not align with the wider Local Plan Strategy”. Endurance Estates consider that this fails to consider the contribution that the Site could make towards a controlled and proportionate growth of the Village in order to support essential services and facilities to maintain the vitality of the village in accordance with paragraph 85 of the NPPF.

Since the development at Hurdleditch Road was approved in 2016 (S/3190/15/OL), no further major schemes have been approved in the village. Partly as a result of the lack of site allocations there within the Adopted Local Plan.

Department of Education records indicate that the Petersfield C of E Primary School has 134 pupils on roll and a capacity of 210, indicating that the school is currently operating at around 64% capacity. This suggests there is capacity for growth within the village, which would help safeguard existing services for the benefit of current and future residents.
The Inset Map for Orwell should be updated to reflect the capacity of the village for a controlled and proportionate level of growth to support the Village’s services. This should include, as a minimum, Land at Hillside, Orwell for a residential development of circa 26 dwellings.
The Site remains Available, Achievable and Suitable for residential development.
Conclusions

Accordingly, for the reasons outlined above, Endurance Estates contends that Policy S/RRA is unsound. By focusing growth almost exclusively on strategic sites and constraining the range and distribution of housing growth by largely excluding growth at sustainable villages, the Plan risks:
• Failing to meet local market and affordable housing needs.
• Increasing commuting and associated congestion and emissions.
• Undermining the vitality and viability of village services and facilities.
• Over-reliance on a small number of large allocations, reducing delivery resilience.
• Failing to capitalise on committed transport investments, including: GCP Greenways and the CSET Busway Mass-rapid transit scheme;.
• Exacerbating affordability pressures and undermining the labour supply and economic growth ambitions of Greater Cambridge.

Accordingly, the policy is not positively prepared, justified, effective or consistent with national policy.

The allocation of a small number of additional, smaller and more easily deliverable sites in the Rest of the Rural Area, such as Endurance Estates sites listed above, would go some way to meeting this need, whilst also strengthening the Council’s slim 5-year housing land housing supply buffer, which by the Council’s own admission, is marginal upon adoption of the Plan.

The Policy Map for Cambridge should be amended to remove the Site at Land East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250) from the Green Belt and allocate it 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.

East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250)

Endurance Estates strongly objects to the proposed Policy Inset Map for Cambridge on the basis that it fails to remove Land East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250) from the Green Belt and does not propose allocation of the site for development.
For the reasons outlined in our response to Policies S/JH, S/DS, S/GB and S/EOC, the Policies Map for Cambridge is considered to be not positively prepared, justified, effective or consistent with national policy and is therefore unsound.
Endurance Estates contend that the Site should be allocated for a mixed-use, residential-led development capable of delivering approximately 1,500 new homes alongside extensive green space, employment land, a primary school and associated infrastructure.
The Policies Map proposes no new releases of land from the Green Belt around the edge of Cambridge for allocations for residential development. This is despite the Edge of Cambridge being acknowledged in the Settlement Hierarchy (Policy S/SE and the Sustainability Appraisal as the second most sustainable location for growth. The Greater Cambridge Green Belt Assessment Review Following Changs to National Policy and Guidance prepared by LUC in July 2026 provides a retrospective consideration of Grey Belt land that has been contrived to fit the Development Strategy already set out. The need for further development around the edge of the City is clear and is evident from the Cities increasing reliance on South Cambridgeshire’s New Settlements to meet its housing needs.
The omission of Land East of Gazelle Way is considered to be unjustified. The Site is in a highly sustainable location on the edge of the City, adjoining existing development on two sides and forms a logical location for significant sustainable growth to help meet the unmet market and affordable housing needs of Cambridge and Greater Cambridge more widely. This case is only strengthened by the continuing residential development which abuts the site to the north and north-west.
Land East of Gazelle Way is a well-contained parcel of Green Belt which is a logical extension to the City and is considered to be Grey Belt land, notwithstanding the conclusions of the LUC Greater Cambridge Green Belt Assessment Review Following Changs to National Policy and Guidance which are disputed. It is considered that there is ample land available to incorporate a green buffer to preserve separation of Cambridge, Fulbourn and Teversham which could provide an enduring and ecologically valuable Green Belt boundary.
The Policies Map should therefore be updated to remove Land East of Gazelle Way, Cherry Hinton (Site ID 115222, HELAA ID 40250) from the Green Belt and to allocate it for a residential-led mixed-use urban extension to the City to provide approximately 1,500 new homes, local centre, employment space, new Country Park and associated community and other infrastructure.
Furthermore, the Policy Map currently excludes the Cambridge East allocation, including the Springstead Village development which is currently part-way through delivery. National Policy is clear with regards to settlement boundaries. The Definition at Appendix B of the NPPF 2026 states that a settlement “Includes cities, towns, villages and other predominantly built-up areas, including land which is allocated or has permission for development which will form part of the built-up area once the development is complete”. This creates a clear disconnect between the extent of existing and committed urban development on the ground and the Green Belt boundaries shown on the Policies Map.