Greater Cambridge Local Plan: Proposed Submission

Recognise Site 40509 as a reasonable and sustainable housing opportunity in Sawston and the site should be included within the Plan's housing allocations.

KWA supports the principle of Policy S/DS and its objective of directing development towards sustainable locations. However, KWA considers that the strategy has not been applied consistently in the distribution and selection of rural housing sites. In particular, the continued exclusion of HELAA Site 40509, land south of Babraham Road and east of H/1C, Sawston, has not been adequately justified when considered against the Council's own settlement hierarchy, the sites selected for allocation and the comparative evidence previously submitted by KWA.

Policy S/DS states that development in the rural area will be focused on Rural Centres and Minor Rural Centres, consistent with the level of local service provision and public transport accessibility. Policy S/SH identifies Sawston as a Rural Centre and describes Rural Centres as the largest and most sustainable villages within Greater Cambridge. By comparison, Melbourn is a Minor Rural Centre, while Duxford and Highfield Caldecote are Group Villages. The Council expressly recognises that Group Villages are generally less sustainable locations for new development than Rural Centres and Minor Rural Centres.

This makes the comparative selection of sites particularly important. The Regulation 19 Plan proposes 60 dwellings at S/RSC/MF in Duxford, 65 dwellings at S/RRA/H in Highfield Caldecote and a further 145 dwellings across S/RRA/ML and S/RRA/CR in Melbourn. These are all settlements of a lower order in the Council's hierarchy than Sawston. The Council is therefore directing a significant amount of housing to lower-order settlements while excluding Site 40509, a site adjoining one of the Plan's largest Rural Centre settlements. This is not to suggest that the allocations in Duxford, Highfield Caldecote or Melbourn are necessarily inappropriate in isolation. Rather, the Council has not demonstrated why those sites are preferred over a smaller site in a more sustainable settlement, particularly where the site-selection evidence is disputed.

KWA has raised this issue consistently throughout the preparation of the Local Plan. In its earlier representations, KWA identified Site 40509 as performing equally or better than sites selected for allocation within both the Rural Southern Cluster and the wider rural area, including on the basis of its more sustainable location. KWA's January 2026 representation subsequently identified specific discrepancies between the HELAA assessment of Site 40509 and allocated sites, giving S/RSC/MF as an example. KWA's review identified that the two sites appeared to have similar ecological contexts and proposed similar levels of development, yet received different HELAA RAG assessments. The representation was supported by comparative material submitted to the Council
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The Council's published evidence does not demonstrate how these specific concerns have been resolved. In particular, it does not demonstrate why the comparative assessment of Site 40509 is considered to be unsound, or why the selected sites represent a more appropriate pattern of development when assessed against the same sustainability and site-selection criteria, which is particularly relevant given the Policy S/SH’s requirement for housing to be first directed towards Rural Centres.

This issue is further strengthened by the change to the site promoted by KWA during the consultations process for this Local Plan. The original site boundary has been substantially reduced so that the proposed development would align with the existing and planned built form associated with H/1B and H/1C and would adjoin the CSETS corridor to the east. KWA considers that this materially changes the site's relationship with the settlement edge and addresses the Council's previous concerns regarding its relationship with the village. The January 2026 representation made by KWA specifically requested that the revised proposition be reconsidered. The Council has not demonstrated through the published evidence supporting the Regulation 19 Plan that this revised site has been reassessed against the alternative sites selected for allocation.

The exclusion of Site 40509 is therefore not adequately justified by the current evidence. The published strategy does not demonstrate that reasonable alternatives have been considered consistently, or that the distribution of rural housing represents the most appropriate strategy having regard to the Council's own settlement hierarchy, the sustainability of different locations and the comparative HELAA evidence. This is particularly significant because Policy S/DS itself seeks to avoid directing a significant proportion of growth to less sustainable locations where car dependency is greater.

The strategy is also not positively prepared insofar as it has not adequately demonstrated that the available opportunities for sustainable housing delivery at one of the Council's most sustainable rural settlements have been properly considered before directing growth to lower-order settlements.

Legal compliance: The Council has not demonstrated that the materially revised proposition for HELAA Site 40509, submitted during the preparation of the Regulation 19 Plan, was properly considered or reassessed before the Plan was finalised. The revised site boundary materially changes its relationship with the existing and planned settlement edge and the CSET corridor. The published evidence continues to rely on the previous site assessment and does not demonstrate that the revised proposition was assessed against the same criteria applied to alternative sites. This raises concerns as to whether the Plan has been prepared in accordance with the statutory plan-making requirements and on a sufficiently robust evidence base.

KWA requests that the Council reconsider Site 40509 as a housing opportunity at Sawston when applying the settlement hierarchy and determining the final distribution of strategic housing allocations.

At a minimum, the Council should publish a clear comparative assessment of Site 40509 against the strategic housing allocations at Duxford, Highfield Caldecote and Melbourn, applying the settlement hierarchy and relevant site-selection criteria consistently and taking account of the reduced site boundary and the changed spatial context arising from CSETS.

For these reasons, while KWA supports the principle and objectives of Policy S/SH, the Plan is not currently demonstrated to be justified or positively prepared in its application of the settlement hierarchy.

KWA supports the principle of Policy S/SH and the use of a settlement hierarchy based on the relative sustainability, services, facilities and accessibility of settlements. However, we consider that the hierarchy has not been applied consistently in determining the location of strategic housing allocations.

Policy S/SH identifies Sawston as a Rural Centre and describes Rural Centres as the largest and most sustainable villages within Greater Cambridge, with good access to secondary education, employment, services and facilities and high-quality public transport. By comparison, Melbourn is identified as a Minor Rural Centre, while Duxford and Highfield Caldecote are identified as Group Villages. The supporting text recognises that Minor Rural Centres have a lower level of services, facilities and employment than Rural Centres and that Group Villages are generally less sustainable locations than Rural Centres and Minor Rural Centres.

This distinction is relevant to the selection of strategic housing sites. The Regulation 19 Plan proposes 60 dwellings at S/RSC/MF in Duxford, 65 dwellings at S/RRA/H in Highfield Caldecote and a further 145 dwellings at S/RRA/ML and S/RRA/CR in Melbourn, while Site 40509 at Sawston remains unallocated. The issue is not that development in these settlements is necessarily precluded by Policy S/SH. Rather, the Council has not demonstrated why housing opportunities in lower-order settlements have been selected while a site adjoining a Rural Centre has been excluded.
KWA has previously raised this issue through its representations on the Plan and has provided comparative evidence identifying discrepancies between the HELAA assessment of Site 40509 and allocated sites, including S/RSC/MF at Duxford. KWA's review identified that the sites appeared to have similar ecological contexts and similar levels of proposed development, but received different HELAA RAG assessments. KWA's January 2026 representation also proposed a reduced site boundary for 40509, specifically addressing the site's relationship with the settlement edge.

The Council has not demonstrated through the published evidence supporting the Regulation 19 Plan how these matters have been resolved. In particular, there is no clear evidence demonstrating why Site 40509 does not represent an appropriate housing opportunity when assessed against the principles of the settlement hierarchy and the sites selected for allocation elsewhere. Nor has the Council demonstrated how the revised 40509 proposition has been considered in the context of its relationship with existing and planned development and the CSETS corridor.

The concern is therefore not with the hierarchy itself, which KWA supports, but with its application. If Sawston is identified as a Rural Centre and one of the most sustainable rural settlements, the Council should be able to demonstrate why a suitably located site adjoining Sawston is not appropriate for housing when substantial housing allocations are being made in settlements which the Council itself identifies as less sustainable.

The failure to demonstrate that the settlement hierarchy has been applied consistently means that the resulting distribution of housing is not adequately supported by proportionate evidence. Policy S/SH is therefore not currently demonstrated to be justified. It is also not positively prepared, insofar as the Plan has not demonstrated that opportunities for sustainable housing delivery at a Rural Centre have been properly considered before directing growth to lower-order settlements.

Legal compliance: KWA considers that the failure to demonstrate that reasonable alternatives, including Site 40509, have been assessed consistently raises a legal compliance concern. The published evidence does not demonstrate that the materially revised 40509 proposition submitted during plan preparation was properly assessed or considered alongside the sites selected for allocation. This raises concerns as to whether the Plan has been prepared on a sufficiently robust evidence base and whether the requirements relating to the consideration of reasonable alternatives have been properly met.

Policy S/RSC should be modified to include HELAA Site 40509, Land to the south of Babraham Road and east of H/1C, Sawston, as an additional housing allocation alongside the sites already identified in the policy.

The allocation should be based on the reduced site boundary promoted by KWA and should take account of:
• the site's location adjoining Sawston, identified by Policy S/SH as a Rural Centre;
• its direct physical relationship with the existing Sawston settlement;
• the reduced site boundary and its relationship with H/1B and H/1C;
• the progression and safeguarding of the CSET corridor;
• its function as a contained/infill parcel rather than an isolated extension into open countryside;
• the correct application of the 2026 Green Belt assessment criteria to the specific parcel;
• the site's previous HELAA assessment and comparative evidence;
• its comparison with the sites selected at Duxford, Caldecote and Melbourn; and
• the benefit of providing additional resilience and flexibility in the delivery of the Plan's housing requirement.

The Council should not rely solely on the existence of alternative sites as a reason for exclusion. Given the modest scale of the additional allocation and the Council's own stated rationale for maintaining headroom in the housing supply, inclusion of 40509 would provide a more robust and resilient housing supply without materially altering the overall spatial strategy.

For these reasons, Policy S/RSC is not justified and not positively prepared in its current form.

KWA objects to Policy S/RSC because the selection of sites within the Rural Southern Cluster is not adequately justified by the evidence supporting the Regulation 19 Plan. In particular, the continued exclusion of HELAA Site 40509, land to the south of Babraham Road and east of H/1C, Sawston, has not been justified when considered against the Council's own site-selection evidence, the settlement hierarchy, the sites selected for allocation, the Green Belt evidence and the materially changed spatial and transport context of the site.

KWA supports the principle of directing an appropriate proportion of development to the Rural Southern Cluster. However, the selection of individual sites must be based on a consistent and proportionate assessment of reasonable alternatives. The supporting text to Policy S/RSC states that alternative sites within the cluster have been considered, having regard to the Development Strategy and the Housing and Employment Land Availability Assessment (HELAA), with sites considered less suitable for development discounted.

Treatment of Site 40509 and the site-selection process

KWA has consistently challenged the exclusion of Site 40509 through the preparation of the Local Plan. The site's treatment during the earlier stages of plan preparation raises a question as to whether it was properly assessed as a distinct site. In the earlier HELAA, Site 40509 was included in the full list of sites and had a detailed site proforma, but 40509a was also identified within the discounted sites as a "duplicated site". KWA raised this apparent discrepancy in its earlier representations.

This is significant because the site subsequently promoted by KWA is not simply the same proposition carried forward unchanged. In January 2026, KWA reduced the red-line boundary to create a substantially more contained development parcel, directly addressing the Council's previous concern regarding the site's relationship with the settlement edge. The Council has not demonstrated through the published evidence supporting the Regulation 19 Plan how this revised proposition has been separately and comprehensively reassessed.

KWA's comparative evidence has also consistently identified that 40509 performs equally or better than sites selected for allocation. This includes S/RSC/MF at Duxford, where KWA identified apparent discrepancies in the HELAA assessment despite similarities in the sites' ecological context and proposed development levels.

Green Belt assessment and changed circumstances

The Council's published reason for excluding 40509 relies substantially on the Green Belt assessment, stating that the 2021 Green Belt Study identifies that release of land in this area would result in a high level of Green Belt harm. It also states that most of the site would not relate well to the village edge, that H/1B and H/1C were intended to create a new village edge, and that further Green Belt release was not necessary to achieve the objectives of those allocations. The Council also states that alternative locations have been identified to meet development needs and that other sites are considered more appropriate.
KWA has reviewed the Council's 2021 and 2026 Green Belt Assessment. The updated assessment continues to identify the site as making a contribution to the Green Belt, but its detailed findings are important. The site is identified as making limited or no contribution to Purpose 1, a moderate contribution to Purpose 2 and a relatively significant contribution to Purpose 3.

KWA considers that the application of the assessment criteria to this particular parcel is incorrect.

For Purpose 2, the assessment criteria for a moderate contribution relates to land which is not associated with an inset settlement. This does not accurately describe Site 40509. The site is physically attached to the eastern edge of existing housing development within the village and directly adjoins and is opposite residential development which forms part of the built-up settlement of Sawston, notwithstanding the administrative parish boundary between Sawston and Babraham. The site is therefore directly and physically associated with the Sawston inset settlement.

The reduced site promoted by KWA would sit directly alongside existing and planned residential development associated with H/1B and H/1C. On this basis, it is not possible for the Purpose 2 assessment to be moderate as the site is associated with an inset village. KWA considers that the appropriate assessment outcome for Purpose 2 should therefore be limited or no contribution, rather than moderate.

The same issue arises in relation to Purpose 3. The 2026 assessment identifies a relatively significant contribution to the purpose of preventing communities in the environs of Cambridge from merging. The criteria for this level of contribution relate to land forming part of a ‘fragile gap’ between settlements.

Site 40509 does not form such a fragile gap. Development of this small parcel would not bring settlements materially closer together because the CSET corridor lies beyond the site and provides a clear physical division between the developed edge of Sawston and the land beyond. This is clearly demonstrated on the Emerging Greater Cambridge Local Plan policies map. The loss of this parcel would not result in the coalescence of settlements in anyway. The proposed development would instead follow the same general line of development established by H/1B and H/1C, particularly having regard to the reduced red-line boundary promoted by KWA in January 2026.

The progression of CSET is particularly important in this respect. Since the earlier Green Belt assessment, CSET Phase 2 has materially progressed, including the proposed busway, travel hub and walking and cycling route. The CSET corridor is now also safeguarded within the Local Plan's spatial and transport framework. This provides a materially different and more clearly defined physical context for the site than existed when the earlier Green Belt assessment was undertaken.

KWA therefore considers that the appropriate assessment for Purpose 3 should also be limited or no contribution as the ‘Land does not lie between neighbouring settlements. It instead lies between H/1:C housing development in Sawston and CSETs.

If the site is assessed correctly against the Council's own criteria for Purposes 2 and 3, the resulting assessment of Green Belt harm would be materially different. The conclusion that release of the land would result in a high level of harm should therefore not be relied upon as a principal reason for excluding this particular parcel without addressing the apparent errors in the underlying purpose assessments.

Changed relationship with the settlement edge

One of the Council's stated reasons for rejecting the original 40509 proposition was that most of the site would not relate well to the village edge. That reasoning does not adequately address the materially different proposition promoted by KWA since the previous consultation in January 2026.

KWA has reduced the red-line boundary so that the proposed development would follow the established and planned line of development associated with H/1B and H/1C. The current Proposed Submission Policies Map also demonstrates the Council's present spatial understanding of the area and identifies the reduced parcel as a contained area between the settlement (incorporating housing to the north and west) and the CSET corridor.

The Council therefore cannot reasonably rely on its earlier conclusion regarding the relationship of the original larger site with the village edge without demonstrating why that conclusion remains applicable to the substantially reduced parcel now proposed and given that CSETs is now clearly defined on the emerging Local Plan policies map.

The circumstances have materially changed since the earlier assessment. H/1B is complete, H/1:C is progressing well with new housing currently being constructed abutting site 40509, the surrounding development has altered the physical relationship between the site and Sawston, CSET has progressed as a strategic transport project, and KWA has materially reduced the site boundary. The evidence used to justify exclusion must be relevant to the site and circumstances being considered at Regulation 19 stage. The Council has not demonstrated that the earlier Green Belt conclusions have been reconsidered in this materially changed context.

Consistency with the sites selected for allocation

The exclusion of 40509 is particularly difficult to reconcile with the range of sites selected by the Council.

Within the Rural Southern Cluster, the Council has selected S/RSC/MF at Duxford for approximately 60 homes. Duxford is identified by Policy S/SH as a Group Village, whereas Sawston is identified as a Rural Centre.

The comparison should not, however, be limited to S/RSC/MF. The wider development strategy also proposes 65 homes at Highfields, Caldecote and 145 homes across two allocations at Melbourn, comprising 20 homes at The Moor and 125 homes west of Cambridge Road. Both Caldecote and Duxford are lower-order settlements within the settlement hierarchy than Sawston, while Melbourn is identified as a Minor Rural Centre.

KWA is not suggesting that development at these locations is inherently inconsistent with the Plan. The issue is whether the Council has demonstrated a sufficiently robust and consistent basis for selecting these sites while excluding 40509.

The Plan is therefore proposing development of:
• approximately 60 homes at Duxford;
• approximately 65 homes at Caldecote; and
• approximately 145 homes at Melbourn,
while continuing to exclude a substantially smaller opportunity adjoining Sawston, a Rural Centre, notwithstanding its proximity to services and facilities, its comparative HELAA evidence and the materially changed circumstances now affecting the site.

The Council's site-selection evidence needs to explain not merely why the selected sites are capable of development, but why 40509 is less appropriate when assessed against the same criteria. The published evidence does not adequately demonstrate this.

"Other alternative sites" and the robustness of housing delivery

The Council's other stated reason for excluding 40509 is that alternative locations have been identified to meet development needs. This does not adequately justify the continued exclusion of 40509.

The purpose of allocating sites is not simply to identify the minimum number of dwellings required. The Council's own Development Strategy recognises the importance of providing headroom to give greater confidence in meeting housing need and to respond to changing circumstances. The current strategy identifies a housing need of 48,069 homes and total supply of 52,032 homes, providing 8.2% headroom. The Council expressly states that this additional supply is intended to provide greater confidence in meeting needs and to respond to changing circumstances.

Against that background, the inclusion of an additional, relatively small site capable of providing approximately 24 homes would not represent an excessive increase in the Plan's housing supply. It would increase the identified supply by only approximately 0.05% of the housing requirement and would increase the current headroom only marginally, from approximately 8.2% to approximately 8.3%.
More importantly, allocating 40509 alongside the sites already identified would ensure that where sites have performed equally well, they are allocated accordingly. It would also provide additional resilience in the housing land supply. It would reduce reliance on the successful delivery of individual allocated sites and provide greater flexibility if delivery rates, infrastructure constraints, viability or other circumstances affect individual allocations during the plan period.
This is particularly relevant given the Council's acknowledgement that the delivery of housing is affected by infrastructure constraints and that the increased annual housing requirement is not anticipated to be met at a sustained level until later in the plan period.

The appropriate response to the identification of alternative sites is therefore not to exclude another sustainable and deliverable opportunity. The Council should consider whether the inclusion of 40509 would provide a more robust and resilient supply of housing, particularly where the additional allocation is modest and the site has a substantially more contained relationship with the existing settlement than the original site proposition and is located in a more sustainable location according to the LPA’s own planning policies.

The inclusion of 40509 would consequently support the Plan's ability to deliver its housing requirement rather than simply increasing the number of sites to an unnecessary level. It would provide a modest additional source of housing supply and greater flexibility should other allocations fail to deliver in full or within the anticipated timescales.

Conclusion

The continued exclusion of Site 40509 is therefore not adequately justified.

The Council's evidence does not adequately address:
• the site's earlier treatment as a potentially duplicated site and whether it was properly assessed as a distinct proposition;
• the material changes to the site's surrounding built form and infrastructure since the 2021 Green Belt assessment;
• the reduced red-line boundary now promoted by KWA;
• the direct physical relationship between the site and the Sawston inset settlement;
• the apparent inconsistency between the 2026 Green Belt assessment criteria and the Purpose 2 and Purpose 3 ratings attributed to this particular parcel;
• the significance of the CSET corridor as a physical division between settlements;
• the comparison between 40509 and the sites selected at Duxford, Caldecote and Melbourn;
• why the identification of other alternative sites is sufficient justification for excluding a further sustainable and contained site; or
• why a modest additional allocation would not provide useful resilience in the delivery of the Plan's housing requirement.

This is not simply a request for the Council to reconsider a previously rejected alternative. It goes to the adequacy and consistency of the site-selection methodology underpinning Policy S/RSC. The Council has selected sites within the Rural Southern Cluster and wider rural area but has not demonstrated through its published evidence that Site 40509, as now promoted, has been assessed on an equivalent and current basis.

KWA does not seek the removal of S/RSC/MF. The appropriate modification is to retain the allocation at Maarnford Farm and additionally allocate the reduced Site 40509 for residential development of up to 24 dwellings, subject to appropriate site-specific requirements relating to access, landscape, drainage, ecology, Green Belt mitigation and other relevant planning matters.

KWA (as Agent) objects (on behalf of Waterbeach Instruments Ltd) to Policy S/RSC/MF insofar as the allocation of Land at Maarnford Farm, without the inclusion of Site 40509 at Sawston, has not been adequately justified through a consistent and transparent comparative site-selection process.
KWA is not seeking the removal of S/RSC/MF. The site may appropriately contribute to housing delivery in the Rural Southern Cluster. The objection is that the Council has not adequately demonstrated why Maarnford Farm should be allocated while the smaller and more contained Site 40509, immediately adjoining Sawston Rural Centre, remains excluded. KWA considers that 40509 should be allocated in addition to, rather than instead of, S/RSC/MF.
Site 40509 and the site-selection process

Site 40509, Land to the south of Babraham Road and east of H/1C at Sawston, was identified through the Call for Sites and assessed through the Council's HELAA. The site was included in the full list of sites assessed and was not identified within the sites considered undeliverable or undevelopable. Its detailed HELAA assessment identified one Amber and two Green ratings.

In its earlier representations, KWA highlighted that 40509 performed comparably with, and in some respects better than, sites subsequently selected for allocation within the Rural Southern Cluster. KWA's 2026 representation identified particular discrepancies between the HELAA assessment of 40509 and that of allocated sites, including S/RSC/MF.

The proposition now being advanced by KWA is also materially different from the larger site originally considered. KWA has reduced the red-line boundary to align with the established and planned development pattern associated with H/1:B and H/1:C. This creates a substantially smaller and more contained development opportunity than the original site.

The Council's published reason for excluding 40509 included the view that most of the site would not relate well to the village edge, that H/1:B and H/1:C would establish a new village edge, and that further Green Belt release was not necessary because alternative locations could meet the development requirement.
KWA considers that these conclusions have not been adequately reconsidered in light of the materially changed circumstances and the reduced site now being promoted.

Green Belt assessment

KWA recognises that 40509 is within the Green Belt and that this is an additional consideration which does not apply to S/RSC/MF.
However, the Council's Green Belt evidence must be considered against the characteristics of the particular site and its current spatial context. The 2026 Green Belt Assessment identifies 40509 as making a limited or no contribution to Purpose 1, a moderate contribution to Purpose 2 and a relatively significant contribution to Purpose 3.

KWA considers that the Purpose 2 and Purpose 3 conclusions do not properly reflect the physical relationship of the site with Sawston.
In relation to Purpose 2, the assessment criterion concerns preventing neighbouring towns from merging into one another and identifies, in particular, the importance of whether land is associated with an inset settlement. Site 40509 is directly associated with the inset settlement of Sawston. It adjoins existing and planned residential development and, in its revised form, follows the established development line of H/1:B and H/1:C. KWA therefore considers that the site should make limited or no contribution to this purpose rather than a moderate contribution.
In relation to Purpose 3, the assessment criterion concerns assisting in safeguarding the countryside from encroachment, including whether land forms a fragile gap between settlements. Site 40509 does not form such a gap. The CSET corridor lies beyond the site and provides a clear physical distinction between the development at Sawston and the wider countryside beyond. Development of the reduced site would not bring neighbouring settlements materially closer together. KWA therefore considers that the relatively significant contribution attributed to Purpose 3 is also not justified.

These points are important because the Council has relied on Green Belt assessment as part of the justification for excluding 40509. The Council should not simply carry forward the conclusions of earlier Green Belt work without demonstrating that those conclusions remain applicable to the reduced site and materially changed site, setting and spatial context.

Changed spatial context

The spatial context around 40509 has changed since the earlier assessments were undertaken. H/1:B and H/1:C have established or progressed the direction of development at this part of Sawston, while the CSET scheme has also progressed through the transport planning process.

The CSET corridor is safeguarded through the Local Plan spatial framework for its intended transport purposes. Once considered alongside the existing housing to the north of the site (H/1:B) and to the west of the site (H/1:C), the reduced 40509 parcel represents a much more contained opportunity than the larger area originally promoted.

This is significant in considering the Council's earlier conclusion that most of the site would not relate well to the village edge. The revised red line follows the development pattern established by H/1:B and H/1:C, while the CSET corridor provides a defined feature beyond the site. KWA therefore considers that the current spatial relationship requires a fresh and site-specific assessment rather than reliance on the conclusions reached in relation to the original larger parcel.
The earlier treatment of the site also warrants clarification. Site 40509a was identified as a duplicated site within the Council's site-selection evidence. Although a detailed HELAA proforma was prepared for 40509, the treatment of the site as a duplication raises a legitimate question as to whether the specific, smaller development proposition now advanced by KWA has been adequately tested as a distinct alternative.

Comparative site selection

KWA recognises that there is an important distinction between S/RSC/MF and Site 40509: S/RSC/MF is not within the Green Belt, whereas 40509 is. KWA is not suggesting that the two sites are identical or that the allocation of S/RSC/MF removes the need to consider Green Belt purposes in relation to 40509.
The relevance of S/RSC/MF is instead the Council's approach to the comparative assessment of settlement relationship, accessibility and sustainability.
The Council considers S/RSC/MF appropriate for allocation because it is well related to Duxford, is close to the village school and is within walking distance of Whittlesford Parkway. The site therefore demonstrates the weight the Council has placed on a site's relationship with an existing settlement and its access to services and sustainable transport when selecting sites within the rural area.
Those considerations are also relevant to 40509. 40509 directly adjoins Sawston, which is identified as a Rural Centre, and has access to the substantially greater range of services and facilities available within Sawston. The revised site also directly adjoins existing and planned residential development associated with H/1B and H/1C and has a materially more contained relationship with the settlement than the larger site originally promoted.

The difference is therefore that 40509 has an additional Green Belt consideration. KWA's case is that this consideration has not been correctly assessed. As set out above, KWA considers that the 2026 assessment incorrectly identifies the site as making a moderate contribution to Purpose 2 and a relatively significant contribution to Purpose 3, when the site is directly associated with the Sawston inset settlement and does not form a fragile gap between settlements.
Once the Green Belt assessment is correctly considered, the Council must still demonstrate why a smaller, contained site immediately adjoining a Rural Centre, with access to a wide range of services and facilities and a defined transport corridor beyond it, should be excluded while a site at a lower-order settlement is allocated.

The comparison with S/RSC/MF therefore goes to the consistency and transparency of the site-selection process, rather than suggesting that the Green Belt status or environmental effects of the two sites are equivalent.
Settlement hierarchy and comparative housing distribution
The wider distribution of housing across the Rural Southern Cluster also raises questions about the exclusion of 40509.

S/RSC/MF provides for approximately 60 dwellings at Duxford, a Group Village. The Plan also proposes significant housing delivery at other lower-order settlements, including Caldecote and Melbourn. This demonstrates that the Council is prepared to direct substantial housing growth to Group Villages and Minor Rural Centres where sites are considered capable of accommodating development.

Sawston is a Rural Centre and is therefore higher in the settlement hierarchy. KWA is not suggesting that settlement hierarchy alone requires the allocation of 40509. However, where a smaller site directly adjoins a Rural Centre and has a strong relationship with the existing settlement, the Council should provide a clear and evidenced explanation for its exclusion, particularly where comparable or larger housing allocations are being made elsewhere within the Rural Southern Cluster.
The issue is therefore not whether Duxford, Caldecote or Melbourn should receive housing. It is whether the comparative site-selection process has adequately tested the relative merits of 40509 against the sites selected for allocation.

Housing delivery and supply resilience

The Council's reliance on alternative sites to meet the housing requirement is also not, in itself, a sufficient reason to exclude 40509.

The Proposed Submission Plan identifies a housing requirement of approximately 48,069 homes and a total supply of approximately 52,032 homes, providing a stated supply margin. The addition of up to 24 dwellings at 40509 would make only a marginal difference to the overall level of planned supply, while providing an additional source of housing delivery in a sustainable location.

KWA is therefore not seeking an approach that would undermine the Plan's overall strategy or require the removal of other allocations. The inclusion of 40509 would instead provide additional flexibility and resilience within the housing supply, particularly where the site is capable of being delivered as a relatively small and contained extension to an existing Rural Centre.

KWA considers that the exclusion of Site 40509 has not been adequately justified when considered against:
• its existing HELAA assessment and sustainability credentials;
• the reduced and more contained site now being promoted;
• its direct relationship with the inset settlement of Sawston;
• the materially changed spatial context created by surrounding development and the progression of CSET;
• the conclusions reached in the 2026 Green Belt Assessment, particularly in relation to Purposes 2 and 3;
• the Council's approach to settlement relationship, accessibility and sustainability demonstrated through the allocation of S/RSC/MF; and
• the opportunity to provide additional housing supply and resilience through a relatively small allocation adjoining a Rural Centre.

KWA therefore considers that Policy S/RSC/MF is not justified and not positively prepared insofar as the comparative site-selection process has not adequately demonstrated why S/RSC/MF should be allocated while Site 40509 remains excluded.

KWA considers that the Plan may not be legally compliant because the Council has not demonstrated that the materially revised proposition for HELAA Site 40509 was properly considered as a reasonable alternative during the preparation of the Regulation 19 Plan.

KWA does not seek the removal or reduction of the S/RSC/SBR allocation.
The requested modification is to retain S/RSC/SBR as proposed and additionally allocate the reduced Site 40509, Land to the south of Babraham Road and east of H/1:C, Sawston, for approximately 24 dwellings.
The additional allocation should be subject to appropriate site-specific requirements relating to access, landscape, drainage, ecology, Green Belt mitigation and sustainable transport.

KWA objects to Policy S/RSC/SBR insofar as the allocation of land south of Babraham Road, Sawston, without the inclusion of Site 40509 immediately to the east of H/1:C, demonstrates an inconsistent approach to the identification of appropriate development land adjoining Sawston.

KWA does not object to the principle of allocating S/RSC/SBR. The site is appropriately recognised as a sustainable location for housing and its allocation is consistent with Sawston's position as a Rural Centre. The concern is that the same principles which support this allocation have not been applied consistently to Site 40509.

Sawston as a sustainable location for development

The Council's own justification for S/RSC/SBR is significant. The policy allocates approximately 280 homes and states that the site provides an opportunity for development in one of the most sustainable villages in the district. It expressly recognises that Sawston is a Rural Centre with many facilities and therefore identifies opportunities for walking and cycling as a means of reducing reliance on the private car.

This provides clear evidence of the Council's current position that Sawston is an appropriate location for significant housing growth because of its position within the settlement hierarchy, its range of services and facilities and its opportunities for sustainable travel.

Those same characteristics apply to Site 40509. The site immediately adjoins the existing built-up area of Sawston and is capable of being integrated with the settlement. KWA's revised proposal is specifically contained within a reduced red-line boundary and follows the established and planned development pattern associated with H/1:B and H/1:C.

The Council has not adequately explained why these locational characteristics support the allocation of 280 homes at S/RSC/SBR but do not support the inclusion of a further, substantially smaller opportunity immediately adjoining the same Rural Centre.

Relationship with the settlement edge

The Council requires S/RSC/SBR to provide a significant landscape buffer along its eastern and northern boundaries where it adjoins farmland, specifically to provide a soft green village edge.

This demonstrates that the Council accepts that development at the edge of Sawston can provide an appropriate and defensible settlement form where suitable landscape measures are incorporated.

The same principle applies to 40509. The revised site boundary promoted by KWA has been reduced so that development would follow the established and planned line of development associated with H/1:B and H/1:C. It would therefore not represent the extensive outward expansion originally considered.

In addition, the now promoted CSETs will provide a landscaping buffer which will create a natural edge to the village that has been missing to date.

The Council's earlier reason for excluding 40509 included the assertion that most of the site would not relate well to the village edge. That conclusion should now be reconsidered in light of the reduced site boundary and the current spatial relationship between the site, H/1B, H/1C and the CSET corridor.

Green Belt and changed circumstances

Unlike S/RSC/SBR, which was previously removed from the Green Belt and allocated for development in the 2018 South Cambridgeshire Local Plan, Site 40509 remains within the Green Belt. The Council's supporting text expressly identifies this distinction and the need for landscape measures to minimise impacts on the adjacent Green Belt.

KWA accepts that the Green Belt status of 40509 requires separate consideration. However, the Council's assessment of the contribution made by the specific parcel must be robust and current.

The 2026 Green Belt Assessment identifies 40509 as making limited or no contribution to Purpose 1, moderate contribution to Purpose 2 and relatively significant contribution to Purpose 3. KWA considers that the Purpose 2 and Purpose 3 assessments do not properly reflect the site's relationship with Sawston.
For Purpose 2, the assessment criteria recognise the importance of whether land is associated with an inset settlement. 40509 directly adjoins the built-up area of Sawston and existing and planned residential development associated with H/1B and H/1C. It is therefore directly associated with the Sawston inset settlement. KWA considers that it should accordingly make limited or no contribution to this purpose rather than a moderate contribution.

For Purpose 3, the relevant consideration is whether land forms a fragile gap between settlements. 40509 does not perform this function. The CSET corridor lies beyond the site and provides a clear physical division between Sawston and the countryside beyond. This is evident on the emerging Policies Map. Development of the reduced parcel would not materially bring neighbouring settlements closer together. KWA therefore considers that the relatively significant contribution attributed to Purpose 3 is not justified.

The Council's current allocation of S/RSC/SBR demonstrates that it is prepared to direct substantial housing growth towards the edge of Sawston where development can be appropriately contained and landscape impacts addressed. The Green Belt assessment of 40509 should therefore be considered on the basis of its actual physical characteristics and current relationship with the settlement, rather than relying on conclusions associated with the larger site originally promoted.

CSET and the current settlement edge

The spatial context has also materially changed since the earlier assessment of 40509.

H/1:B and H/1:C have completed or progressed (respectively) development along this part of Sawston, while CSET has progressed through the transport planning process and its corridor is safeguarded within the Local Plan framework.

This is important because the Council's earlier approach treated H/1:B and H/1:C as establishing a new village edge beyond which further Green Belt development was considered inappropriate.

The current position is different. The reduced 40509 site would sit alongside the established and planned development at H/1:C but in line with that planned at H/1:B, with the CSET corridor further east. The combined effect is to create a considerably more contained development opportunity than the original site considered through the earlier stages of plan preparation.

The Council should therefore explain why the current spatial context does not justify reconsideration of 40509, particularly when it has accepted the principle of substantial housing growth around Sawston through S/RSC/SBR.

Consistency of site selection

KWA previously submitted representations that Site 40509 performs equally or better than sites selected within the Rural Southern Cluster, including in relation to access to services and sustainable development.

The current allocation of S/RSC/SBR reinforces this point. The Council has expressly relied upon Sawston's status as a Rural Centre, its range of facilities and its opportunities for active travel in justifying a substantial housing allocation in allocating S/RSC/SBR. It was rated Green for accessibility. Despite site 40509 being adjacent to this site and as equally well connected, site 40509 received an Amber rating. Those same characteristics cannot reasonably be disregarded when considering a smaller site immediately adjoining the same settlement. There are a number of similar discrepancies which unreasonably harm site 40509's potential as an allocated site compared to alternatives. These were highlighted in January 2026's consultation (see attachments to this submission) but no change in assessment appears to have been undertaken and this appears not to have been rectified.

KWA recognises that the two sites are not identical. S/RSC/SBR is outside the Green Belt, whereas 40509 is within it. However, that distinction does not remove the requirement for the Council to demonstrate that the Green Belt evidence has been correctly applied to 40509 and that the site's exclusion remains justified when its current spatial context is taken into account. The Council has not adequately demonstrated this.

Housing delivery

The allocation of approximately 280 homes at S/RSC/SBR demonstrates the Council's reliance upon Sawston as an important location for meeting housing need within the Rural Southern Cluster.

The inclusion of 40509 would complement rather than undermine this approach. The reduced site could provide approximately 24 additional homes, making only a marginal contribution to the overall housing supply while providing an additional source of delivery within one of the Council's identified sustainable rural locations.
The Council's reliance on alternative sites elsewhere should therefore not, in itself, justify the exclusion of 40509. Additional sites can provide greater resilience in housing delivery and reduce reliance on the successful delivery of individual allocations.

This is particularly relevant where the site is immediately adjoining an established Rural Centre and has been demonstrated through the previous site-selection process to be capable of development.

Conclusion

KWA considers that Policy S/RSC/SBR provides further evidence that the Council recognises Sawston as an appropriate location for significant housing development because of its position within the settlement hierarchy, range of services and facilities and opportunities for sustainable travel.

The Council has not adequately explained why those same characteristics do not support the inclusion of Site 40509, particularly given:

• the reduced and more contained site now promoted by KWA;
• its direct relationship with the Sawston inset settlement;
• the existing and planned development at H/1:B and H/1:C;
• the progression and safeguarding of CSET;
• the changed spatial context since the earlier Green Belt assessment;
• the concerns regarding the application of the 2026 Green Belt assessment to Purposes 2 and 3; and
• the relatively modest additional housing contribution that the site could make.

KWA therefore considers that Policy S/RSC/SBR is not justified and not positively prepared insofar as the Council has not demonstrated a consistent and adequately evidenced approach to the selection of development sites adjoining Sawston, contrary to its legal duties.

KWA requests that the Council:
• retains the overall approach of Policy S/RRA;
• ensures that its site-selection methodology is applied consistently to all promoted sites;
• reviews the assessment of Site 40509 against the current settlement and Green Belt context; and
• includes the reduced Site 40509 for up to approximately 24 dwellings within the Local Plan's housing allocations.
This would not require the removal of any existing S/RRA allocation and would provide additional housing delivery at a site directly adjoining an established Rural Centre.

KWA supports the principle of allocating appropriate sites within the rural area to contribute towards housing and employment needs and to support the vitality of rural communities. However, KWA considers that the approach set out in Policy S/RRA is not fully justified or positively prepared because the stated principles for identifying sustainable rural sites have not been applied consistently across the Plan.

The supporting text states that, within the rest of the rural area, sites have been allocated in locations with sustainable access, including Rural Centres, Minor Rural Centres and Group Villages with very good public transport access. It also confirms that site selection has been informed by Green Belt considerations and the availability of alternative sites.

These principles are relevant to the wider treatment of Site 40509 at Sawston. Sawston is a Rural Centre and 40509 directly adjoins the existing settlement and planned residential development. KWA's HELAA assessment identified the site as within or adjacent to a Rural Centre, with one Amber and two Green ratings. The revised site now promoted is also substantially smaller and more contained than the original parcel.

The Council's approach to Green Belt land also requires careful consideration. Policy S/RRA states that Green Belt sites were tested but that the Council concluded there were no exceptional circumstances for meeting general need in light of alternatives available. This does not, however, remove the need for the Council to demonstrate that individual Green Belt sites have been assessed appropriately against their particular circumstances.

In the case of 40509, KWA considers that the 2026 Green Belt Assessment does not properly reflect the site's relationship with Sawston. The site is directly associated with the inset settlement and does not form a fragile gap between settlements. KWA therefore considers that the moderate contribution attributed to Purpose 2 and relatively significant contribution attributed to Purpose 3 are not justified for the reduced parcel. The materially changed spatial context, including the completion and progression of H/1:B and H/1:C respectively and the CSET corridor, should also be reflected in the assessment.

The policy also states that the number of rural allocations has been balanced against the sustainability considerations of the overall strategy. KWA considers that this approach should not result in suitable and sustainable smaller sites being excluded simply because other sites are available. Site 40509 could provide up to approximately 24 additional homes in a location directly adjoining a Rural Centre, providing additional housing delivery and resilience without requiring the removal of existing allocations.

KWA therefore considers that the Council should demonstrate more clearly how the principles in Policy S/RRA, particularly sustainable access, settlement relationship, Green Belt assessment and the consideration of alternative sites, have been applied consistently to 40509 and other sites selected for allocation.
Conclusion

Policy S/RRA is not justified and not positively prepared as the Council's stated approach to the selection of sustainable rural sites has not been demonstrated to have been applied consistently.

KWA does not seek the removal of S/RRA/ML. The appropriate modification is to retain the allocation at The Moor and additionally allocate the reduced Site 40509 at Sawston for up to approximately 24 dwellings, subject to appropriate site-specific requirements.

KWA objects to Policy S/RRA/ML insofar as the allocation of The Moor for 20 dwellings, while Site 40509 at Sawston remains excluded, has not been adequately justified through a consistent comparative assessment of sites within the rural area.

KWA is not seeking the removal of S/RRA/ML. The site may appropriately contribute to housing delivery at Melbourn. The issue is whether the Council has applied its site-selection principles consistently when a smaller site directly adjoining Sawston Rural Centre remains excluded.

Comparative site selection

The Council's approach to the Rest of the Rural Area is to direct development towards villages with good transport links and services, while restricting development in smaller settlements where car travel is more likely to be necessary. The Plan allocates 20 homes at S/RRA/ML, alongside a further 125 homes at S/RRA/CR in Melbourn and 65 homes at S/RRA/H in Caldecote.
Site 40509 has a strong relationship with Sawston, which is a Rural Centre with a substantially greater range of services and facilities. The site directly adjoins the existing and planned development of Sawston and is therefore closely related to an established settlement rather than being an isolated rural site.
KWA's HELAA assessment identified 40509 as within or adjacent to a Rural Centre, with one Amber and two Green ratings. KWA has subsequently reduced the site boundary to create a more contained development opportunity, aligned with the established and planned development pattern associated with H/1:B and H/1:C.

The Council has not adequately explained why these characteristics do not justify the inclusion of 40509, particularly when development is being directed towards lower-order settlements elsewhere in the rural area.

Green Belt and spatial context

KWA recognises that 40509 is within the Green Belt and that this is an important distinction from S/RRA/ML. The allocation of S/RRA/ML does not, in itself, establish that 40509 should be released from the Green Belt.

However, the Green Belt assessment must be properly applied to the specific site. The 2026 Green Belt Assessment identifies 40509 as making limited or no contribution to Purpose 1, moderate contribution to Purpose 2 and relatively significant contribution to Purpose 3.

KWA considers that the latter conclusions do not properly reflect the site's relationship with Sawston. The reduced 40509 parcel is directly associated with the inset settlement and does not form a fragile gap between settlements. The CSET corridor provides a defined physical feature beyond the site, while surrounding development has progressed since the earlier assessment.

KWA therefore considers that the Purpose 2 and Purpose 3 conclusions require reconsideration in light of the current site boundary and spatial context. This is particularly important because the Council has relied on Green Belt considerations and the availability of alternative sites when determining which sites should be allocated.

Housing delivery and settlement hierarchy

The allocation of S/RRA/ML also demonstrates that the Council considers additional housing delivery at lower-order settlements appropriate where sites are considered capable of contributing to the Plan's strategy.
KWA is not suggesting that housing should be redistributed from Melbourn to Sawston. Rather, the comparison demonstrates the need for a transparent and consistent explanation of why a site directly adjoining a Rural Centre should remain excluded while housing is allocated at a Minor Rural Centre.

The addition of up to approximately 24 homes at 40509 would make only a marginal difference to the Plan's overall housing supply, while providing additional housing delivery and resilience in a location directly adjoining an established Rural Centre. The Plan currently provides approximately 8.2% headroom above its identified housing need, with site 410509, this would increase marginally to 8.3%.

KWA considers that Policy S/RRA/ML is not justified and not positively prepared insofar as the Council has not adequately demonstrated that its site-selection methodology has been applied consistently to Site 40509.

KWA does not seek the removal of S/RRA/H. The appropriate modification is to retain the allocation at Highfields and additionally allocate the reduced Site 40509 at Sawston for up to approximately 24 dwellings, subject to appropriate site-specific requirements.

The allocation of S/RRA/H should not be regarded as a reason to exclude 40509 without a clear and evidenced explanation of why the Council's stated criteria for sustainable rural development lead to different conclusions for the two sites.

KWA objects to Policy S/RRA/H insofar as the allocation of approximately 65 homes at Highfields, Caldecote, while Site 40509 at Sawston remains excluded, has not been adequately justified through a consistent comparative assessment of sites within the rural area.

KWA is not seeking the removal of S/RRA/H. The site may appropriately contribute to housing delivery at Caldecote. The issue is whether the Council has applied its site-selection principles consistently when a smaller site directly adjoining Sawston Rural Centre remains excluded.

Comparative site selection

The Council's approach to the Rest of the Rural Area is to identify sites in or adjoining Rural Centres, Minor Rural Centres and Group Villages where there are good opportunities for sustainable travel. The Council states that site selection has been informed by the HELAA, environmental impacts and sustainable travel opportunities.

S/RRA/H is a 3.74 hectare site allocated for approximately 65 homes. The Council considers it suitable in part because it is adjacent to existing development and close to a proposed public transport corridor. The policy also requires connections to the existing bridleway forming part of the wider Highfields development and links to proposed public transport.

Site 40509 has similarly been identified through the HELAA as a potential residential site within or adjacent to a Rural Centre. Its assessment included one Amber and two Green ratings. The revised site now promoted by KWA is substantially smaller than the original proposal and directly adjoins the established and planned development of Sawston.

The distinction between the sites is not that they are identical. S/RRA/H benefits from a previous planning permission and a particular relationship with planned public transport infrastructure. Rather, the comparison demonstrates that the Council is prepared to allocate housing at a Group Village where a site has a good relationship with existing development and opportunities for sustainable travel, while excluding a smaller site directly adjoining a Rural Centre.

In addition, the RAG assessment we provided in January 2026 highlighted that the same summary for Noise and Vibration was applied to 40509 and S/RRA/H, yet 40509 was designated Amber whilst S/RRA/H was designated a Green. Despite this being highlighted in January 2026 to the Council, it appears that no reassessment was undertaken and site 40509 remains unallocated.

The Council has not adequately explained this difference in the context of its stated site-selection methodology.

Green Belt and spatial context

KWA recognises that 40509 is within the Green Belt and that this is an important distinction from S/RRA/H. The allocation of S/RRA/H does not, in itself, establish that 40509 should be released from the Green Belt.

However, the Green Belt assessment must be properly applied to the particular site. The 2026 Green Belt Assessment identifies 40509 as making limited or no contribution to Purpose 1, moderate contribution to Purpose 2 and relatively significant contribution to Purpose 3.

KWA considers that the Purpose 2 and Purpose 3 conclusions require reconsideration. The reduced 40509 parcel is directly associated with the inset settlement of Sawston and does not form a fragile gap between settlements. The CSET corridor provides a defined physical feature beyond the site, while the surrounding development pattern has progressed since the earlier assessments.
The Council's reliance on Green Belt considerations as a reason for excluding 40509 should therefore be supported by a site-specific assessment which reflects the revised boundary and current spatial context.

Settlement hierarchy and housing delivery

Caldecote is a Group Village, whereas Sawston is a Rural Centre. KWA is not suggesting that settlement hierarchy alone requires the allocation of 40509, but it is a relevant consideration in assessing the relative sustainability of sites.

The allocation of 65 homes at S/RRA/H demonstrates that the Council considers substantial housing growth appropriate at a Group Village where the site has an appropriate relationship with the settlement and sustainable transport opportunities. 40509 directly adjoins the Sawston, a Rural Centre, and would provide up to approximately 24 additional homes in a substantially more contained location.

The addition of 40509 would make only a marginal difference to the Plan's overall housing supply while providing additional housing delivery and resilience. The Proposed Submission Plan currently provides approximately 8.2% headroom above the identified housing requirement and if 40509 was included within the plan it would increase to 8.3%.

KWA considers that Policy S/RRA/H is not justified and not positively prepared insofar as the Council has not adequately demonstrated that its site-selection methodology has been applied consistently to Site 40509.

KWA does not seek the removal of S/RRA/CR. The appropriate modification is to retain the allocation at Land west of Cambridge Road, Melbourn, and additionally allocate the reduced Site 40509 at Sawston for up to approximately 24 dwellings, subject to appropriate site-specific requirements.

At minimum, the Council should undertake a fresh comparative assessment of 40509 against the rural sites selected for allocation, taking account of:

• Sawston's higher position in the settlement hierarchy;
• the direct relationship of 40509 with the existing settlement;
• the reduced and more contained site boundary;
• the current spatial context, including H/1:B, H/1:C and the CSET corridor;
• the 2026 Green Belt assessment and the correct application of Purposes 2 and 3; and
• the contribution that a further 24 homes could make to housing delivery and supply resilience.

The allocation of S/RRA/CR should not, in itself, be regarded as a reason to exclude 40509 without a clear and evidenced explanation of why the Council's stated principles for directing rural growth lead to different conclusions for the two sites.

KWA objects to Policy S/RRA/CR insofar as the allocation of approximately 125 homes at Melbourn, while Site 40509 at Sawston remains excluded, has not been adequately justified through a consistent comparative assessment of sites within the rural area.

KWA is not seeking the removal of S/RRA/CR. The site may appropriately contribute to housing and employment growth at Melbourn. The objection is that the Council has not adequately explained why substantial growth is considered appropriate at a Minor Rural Centre while the smaller Site 40509, directly adjoining the higher-order Rural Centre of Sawston, remains excluded.

Comparative site selection

The Council's justification for S/RRA/CR identifies the opportunity to provide homes in a Minor Rural Centre alongside the expansion of Melbourn Science Park. The current policy requires the development to integrate with Melbourn's existing and proposed built form and includes measures to address its landscape and heritage sensitivities.

The site therefore demonstrates that the Council considers substantial development appropriate where it has a strong relationship with an existing settlement, can integrate with existing or planned development and can contribute to the wider sustainability and vitality of the settlement.

Those principles are also relevant to Site 40509. 40509 directly adjoins Sawston, which is a Rural Centre, and has access to the substantially greater range of services and facilities available within the settlement. It also adjoins existing and planned residential development associated with H/1:B and H/1:C.
KWA's HELAA assessment identified 40509 as within or adjacent to a Rural Centre, with one Amber and two Green ratings. The site now promoted is also materially smaller than the original proposal, with the revised red-line boundary following the established and planned development pattern.

The Council has not adequately explained why these characteristics do not justify the inclusion of 40509, particularly when it considers a substantially larger development appropriate at a lower-order settlement.

Settlement hierarchy and scale of growth

The difference in settlement hierarchy is significant. Melbourn is identified as a Minor Rural Centre, whereas Sawston is a Rural Centre. KWA is not suggesting that settlement hierarchy alone requires 40509 to be allocated, but it is a relevant consideration when assessing the comparative sustainability of sites.
The allocation of 125 homes at S/RRA/CR demonstrates that the Council is prepared to direct substantial housing growth to a Minor Rural Centre where the site has an appropriate relationship with the settlement and opportunities to integrate development with existing infrastructure and employment.
Against this context, the exclusion of a smaller site directly adjoining a Rural Centre requires a clear and evidenced explanation. The Council should demonstrate why the principles that support S/RRA/CR do not also support 40509.
The comparison is not that the two sites are identical. S/RRA/CR has a specific opportunity to integrate with Melbourn Science Park and therefore has additional employment benefits. The point is that employment benefits do not, by themselves, explain the exclusion of 40509 as a residential site where 40509 has stronger settlement-hierarchy credentials and a direct relationship with an established Rural Centre.

Green Belt and spatial context

KWA recognises that 40509 is within the Green Belt and that this is an important distinction from S/RRA/CR.

However, the Green Belt assessment must properly reflect the characteristics of the particular 40509 site. The 2026 Green Belt Assessment identifies 40509 as making limited or no contribution to Purpose 1, moderate contribution to Purpose 2 and relatively significant contribution to Purpose 3.

KWA considers that the Purpose 2 and Purpose 3 conclusions require reconsideration.

For Purpose 2, 40509 is directly associated with the inset settlement of Sawston. It adjoins existing and planned residential development and, in its revised form, follows the established development pattern associated with H/1:B and H/1:C. KWA therefore considers that the site should make limited or no contribution to Purpose 2 rather than a moderate contribution.

For Purpose 3, 40509 does not form a fragile gap between settlements. The CSET corridor provides a defined physical feature beyond the site and development of the reduced parcel would not bring neighbouring settlements materially closer together. KWA therefore considers that the relatively significant contribution attributed to Purpose 3 is not justified.

These matters are particularly relevant because the Council's exclusion of 40509 has relied in part upon Green Belt considerations and the availability of alternative locations. The materially changed spatial context, including the progression of H/1:B and H/1:C, the progression and safeguarding of CSET and the reduced 40509 boundary, should be reflected in the assessment.

Housing delivery and supply resilience

The allocation of 125 homes at S/RRA/CR demonstrates the Council's willingness to use rural allocations to make a significant contribution to housing delivery.
The addition of up to approximately 24 homes at 40509 would be modest in comparison and would make only a marginal difference to the Plan's overall housing supply. It would nevertheless provide an additional source of housing delivery in a location directly adjoining a Rural Centre.

The Proposed Submission Plan identifies approximately 52,032 homes against a housing requirement of approximately 48,069, providing 8.2% headroom. The inclusion of 40509 would therefore provide additional resilience without requiring the removal or reduction of S/RRA/CR or any other allocation.

KWA considers that Policy S/RRA/CR is not justified and not positively prepared insofar as the Council has not adequately demonstrated that its site-selection methodology has been applied consistently to Site 40509.

KWA supports the overall approach to sustainable transport and connectivity in Policy I/ST and, in particular, the safeguarding of land for the Cambridge South East Transport (CSET) scheme on the Proposed Submission Policies Map. This provides a clear spatial framework for the delivery of strategic public transport infrastructure and demonstrates how sites located close to the proposed corridor can be appropriately integrated with sustainable transport networks.
This is particularly relevant to Site 40509, which lies immediately adjacent to the safeguarded CSET corridor. The identification of the CSET route and associated infrastructure on the Policies Map provides greater certainty regarding the future transport context of this part of Sawston and demonstrates that development in this location can be planned alongside strategic public transport provision, walking and cycling connections.
The Council should therefore ensure that the site-selection process takes full account of this changed spatial and transport context. The proximity of sites such as 40509 to the safeguarded CSET corridor is a material sustainability consideration and supports their potential to form well-integrated extensions to the existing settlement.
KWA also considers that future infrastructure associated with CSET and other strategic transport improvements should seek to maximise benefits for pedestrians, cyclists and equestrian users, including through the retention, enhancement and appropriate integration of existing public rights of way and bridleway networks. This would help ensure that new infrastructure strengthens connectivity for all sustainable and active modes, including those particularly relevant to rural communities.
KWA therefore supports Policy I/ST and the safeguarding of the CSET corridor, but considers that its implications should be reflected consistently in the assessment and selection of sites for development, including Site 40509.