Greater Cambridge Local Plan: Proposed Submission

Review the Green Belt evidence underpinning Policy S/GB, including the assessment of Site 40509, and amend the supporting text and associated Green Belt conclusions where the evidence does not accurately reflect the site's contribution to the Green Belt purposes and its current spatial context.

KWA does not object to the principle of protecting the Cambridge Green Belt. However, Policy S/GB should make clear that the Green Belt has a positive as well as a restrictive function. National planning policy does not regard Green Belt land as land to be protected simply for its own sake. It requires Green Belt policy to prevent inappropriate development and maintain openness and the purposes of including land within it, but also requires authorities to plan positively to enhance its beneficial use, including opportunities for access, outdoor recreation, biodiversity and other appropriate uses.

This positive function is particularly relevant to the rural Green Belt around Greater Cambridge, where land provides opportunities for public access, walking, cycling, equestrian activity and recreation, as well as landscape and biodiversity benefits. The policy should therefore recognise that the purpose of the Green Belt is not simply to restrict development, but to manage land in a way that delivers its wider environmental, recreational and social benefits.

KWA is concerned, however, that the application of Policy S/GB places disproportionate reliance on the protection of the Green Belt without sufficient assurance that the evidence identifying the contribution of individual areas is accurate and up to date. The principle of protecting the Green Belt is not disputed, but decisions should be based on a robust assessment of the actual contribution made by individual areas to the purposes of Green Belt designation and the circumstances that exist at the time of plan-making.

This is particularly important in relation to Site 40509. The Council's 2026 Green Belt Assessment identifies the site 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 latter two conclusions do not accurately reflect the site's physical relationship with Sawston and the surrounding development.

In particular, Site 40509 is directly associated with the inset settlement of Sawston and does not perform the function of a fragile gap between settlements. The safeguarded CSET corridor provides a clear physical division beyond the site, while the reduced site boundary promoted by KWA follows the established and planned development pattern. Development within this reduced area would therefore not result in the type of settlement coalescence or loss of separation suggested by the Purpose 2 and Purpose 3 assessments.

The significance of this is not limited to the assessment of Site 40509 itself. The supporting text to Policy S/GB relies upon the Green Belt assessments to underpin the Plan's approach to the Green Belt. Where those assessments do not accurately reflect the circumstances of an individual area, there is a risk that the policy is applied on the basis of an incorrect assessment of Green Belt contribution. The Council should therefore not rely on the assessment of Site 40509 as justification for its continued exclusion from the development strategy without addressing the specific matters identified above.

The circumstances surrounding Site 40509 have also materially changed since the earlier Green Belt evidence was prepared, including the progression and safeguarding of the CSET corridor and changes to the pattern of development around the site. The Council needs to demonstrate that the conclusions relied upon remain appropriate in this changed context and that the 2026 assessment has properly applied its own criteria to the site.

KWA therefore considers Policy S/GB to be not justified and not positively prepared insofar as its supporting evidence does not provide a sufficiently accurate and robust basis for the treatment of individual areas of Green Belt, including Site 40509. The policy should be supported by an accurate, site-specific assessment of Green Belt contribution and should recognise both the restrictive and positive functions of Green Belt land.

Policy S/DS should be modified to recognise Site 40509 as a reasonable and sustainable housing opportunity in Sawston and the site should be included within the Plan's housing allocations. At a minimum, the Council should undertake and publish a consistent comparative assessment of Site 40509 against the rural sites selected for allocation, including S/RSC/MF, S/RRA/ML, S/RRA/H and S/RRA/CR to ensure that the plan is legally compliant. That assessment should take account of the site's position within the settlement hierarchy, accessibility, sustainability, the revised site boundary and the materially changed locational ad Green Belt context arising from CSETS.

For these reasons, Policy S/DS is not currently demonstrated to be justified or positively prepared and the plan is not currently legally compliant.

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.