Greater Cambridge Local Plan: Proposed Submission

This response has been prepared by Ceres Property on behalf of Places for People to support the promotion of land to the North and West of Wilbraham Road, Fulbourn.

PfP supports the vision for Greater Cambridge to be a place where a big decrease in our climate and environmental impacts comes with the continued flourishing of the internationally significant innovation economy, and a big increase in the quality of everyday life for all our communities.

Achieving this vision is contingent upon the adoption of a sound Local Plan which sets ambitious targets for growth and is positively prepared, justified, effective, and consistent with national policy (in accordance with the tests set out in Paragraph 36 of the National Planning Policy Framework 2024 (NPPF). As set out within these representations, in its current form the DLP requires amendments to ensure that the level of growth and housing allocations reflect the Vision for Greater Cambridge as set out in the DLP.

PfP supports a vision focused on:
• A net‑zero future through low‑carbon, climate‑responsive development.
• Nature‑rich places delivering strong biodiversity gains.
• Compact, well‑connected communities focused on sustainable travel.
• Healthy, high‑quality neighbourhoods with excellent design and green space.
• A balanced housing mix meeting diverse local needs.
• A thriving innovation economy supported by homes and infrastructure.
• Resilient water systems addressing scarcity and integrating SuDS.
• Protected landscapes and heritage shaping high‑quality growth.
• Infrastructure aligned with growth, including transport and community facilities.
• Vibrant villages and centres strengthened by improved services and access.

The vision is aligned with PfP own prioritises as set out within the Thriving Communities document (Appendix B) and the site aligns with these objectives and can deliver a development that reflects the distinctive character of Fulbourn while contributing to the wider needs of Greater Cambridge.

Policy S/JH: New Jobs and homes
Development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for:
a) 90,936 additional jobs to support the Greater Cambridge’s knowledge intensive sectors, and also provide a diverse range of local jobs; and
b) A minimum of 59,409 new homes (reflecting an annual need for 2,829 dwellings) meeting the needs for the total population, including for affordable housing and the specialist accommodation needs of specific groups such as Gypsies, Travellers, Travelling Showpeople, looked after children, older people, students, those with disabilities, and boat dwellers

As set out in these representations, sustainable sites which can be delivered early in the plan period, such as Land to the north and west of Wilbraham Road, Fulbourn, would support this ambitious level of growth and should be allocated in the DLP.

This response has been prepared on behalf of PfP and should be reviewed in conjunction with our full consultation report, response which is attached.

The Local Development Scheme currently envisages Adoption of the plan in 2028 and the plan period will cover a period until 2045.

Paragraph 22 of the NPPF states that strategic policies should look ahead to a minimum of 15 years period from adoption to anticipate and respond to long term requirements and opportunities, such as those arising from infrastructure. Where large scale developments such as new settlements or significant extensions to existing villages or towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take account of the timescale for delivery.

The emerging Local Plan proposes a number of new settlements and significant urban extensions, which make up the vast majority of growth in the plan. Table 2 of the emerging Local Plan sets out a housing trajectory for the draft allocated sites. All the larger strategic draft allocations have a growth trajectory that is well in excess of the plan period.

In October 2025 the Greater Cambridgeshire and Peterborough Combined Authority Board approved the Local Growth Plan which has a core ambition to double the size of the area by 2050. The Local Growth Plan looks ahead to 2050, and the government has also set out a vision for growth in Cambridge between now and 2050.

Following the publication of the Local Growth Plan, the Greater Cambridgeshire and Peterborough Combined Authority are now in the process of preparing a Spatial Development Strategy for their area which will be built on the Local Growth Plan and will include geographical and land-use designations. The mayor has committed to publication of a draft version of this plan by 2026, with a view to adopting the Spatial Development Strategy in 2028.

There will be a requirement for the new Local Plan to align with the mayor’s spatial strategy, particularly given they are both due for adoption in 2028.

Therefore, to align with the Cambridgeshire Local Plan and emerging Spatial Development Strategy, and accounting for the number of large strategic allocations in the plan, it is considered that the plan period should be extended to 2050. A longer plan period is considered to clearly be the most reasonable strategy, when considered against the alternatives. This amendment is required in order for the plan to accord with national policy and for it to be justified.
Proposed Amendment to the Vision in order for the Plan to be Sound

In order for the plan to be positively prepared, justified and therefore sound and , the plan needs updating throughout to provide a plan period of 2024-2050. This would need to include amendments to the Vision and policy S/JH to provide a plan period from 2024-2050.

The increase in the length of plan period, will have a resulting impact in the need to plan for additional housing and employment, which will need to be reflected throughout the plan.
Policy S/JH: New Jobs and Homes

Policy S/JH New Jobs and Homes, sets out that development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for: 73,300 additional jobs and a minimum of 48,069 new homes. The number of new homes has had a minor reduction from 48,195 proposed as part of the Regulation 18 stage.

As set out in detail within our Regulation 18 response, the level of employment and housing growth proposed over the plan period is underpinned by the Employment and Housing Evidence Update 2025 (EHEU 2025), which forms an evidence based document that has not been updated since the Regulation 18 version of the Local Plan. The two key drivers for the proposed job and housing growth appears to be predicated mainly on how many jobs the government’s mandatory minimum housing need calculation would support, and separately the most likely future forecast for jobs for Greater Cambridge and the homes that this would require.

The Regulation 19 consultation includes an updated Development Strategy Topic Paper (June 2026) to justify the level of growth proposed. This Development Strategy Topic Paper sets out that between 2024-2045, the current supply of sites (either allocated or sites with planning permission) is 38,378, which leaves a residual requirement to allocate 9,691 to meet Greater Cambridge’s objectively assessed housing needs during the plan period. The emerging Local Plan allocates 13,654 new dwellings from new allocations, which the Development Strategy Topic Paper and emerging Local Plan states provides an 8.2% supply in headroom in relation to housing need.

As set out within the June 2026 Development Strategy Topic Paper, the Councils commissioned a review of economic data having regard to representations made at Regulation 18 stage. In this regard Iceni were commissioned to prepare a Review of Economic Data, Context and Representations (June 2026). and concluded that recent data is not considered to provide sufficient basis for reviewing the EHEU (2025) and that in the view of the Council, the proposed housing and employment growth forecast remains robust.

The earlier version of the Development Strategy Topic Paper (2025) included the below table which sets out the Standard Method, Central and High projected job increases and housing needs (Figure 3 within the attached report). This table has been removed from the June 2026 version, but it is included below as it is considered to provide an important overview of the range of job and growth forecasts considered at earlier stages of the plan making process.



For jobs, the EHEU 2025 identifies a “Central” most likely future jobs forecast. The Central forecast assumes growth of around 4,000 additional jobs per annum or more through to 2045. This is set out as a mixture of continuing the recent period of rapid growth seen in Greater Cambridge’s Knowledge Intensive sectors over the last 10 years, but also building in an assumption that there will be slower or contracting periods and unforeseen shocks. The EHEU 2025 also identifies a higher growth forecast, placing greater weight on what is described as ‘rapid growth in the recent past’, particularly in key sectors, and recommended providing flexibility in employment land in case the market delivers more jobs than anticipated.

For homes, the EHEU 2025 identifies that the outcome of the Government’s Standard Method for calculating minimum housing need, which increased significantly in 2024, would support the most likely forecast for future jobs.

It is argued that as the Standard Method figures broadly correlate with the Central (suggested most likely) job and housing projections and that adoption of these figures is appropriate. However, for reasons explained within this representation, the level of growth proposed does not align with either the government’s, or the Cambridgeshire and Peterborough Combined Authorities aspirations for growth within Greater Cambridge. It also does not provide sufficient flexibility to increase housing numbers, should employment growth continue at the pace it has for the last 10 years. In this regard, there is considered to be a very strong case that employment growth in Cambridge will continue at the pace it has for the last 10 years and that this should be the minimum level of growth planned for.

The Iceni Review of Economic data, context and representations report (June 2026) seeks to support the Councils position on the basis that maintaining growth rates in line with historic growth rates, means ever increasing year on year actual change, which in the view of Iceni and the Council is difficult to achieve over time. However, this does not account for Cambridge being an international and national focus for job growth and it is considered that clearly Cambridge is an exceptional case when considered against other areas of the United Kingdom.

Therefore, in accordance with the requirements of the NPPF, this is not considered to be appropriate strategy taking into account reasonable alternatives and other publicly available evidence. As it stands, for reasons explained below, Policy S/JH is not justified and the DLP could not be found sound.

Paragraph 36 a) of the NPPF is clear that to be positively prepared, the Local Plan should as a minimum, seek to meet the areas objectively assessed housing needs.’ Therefore, the standard method housing requirement should be a minimum starting point for housing growth. Therefore, it is unclear why the Development Strategy Topic Paper (2025) identifies housing figures that are marginally below the standard method requirements for both housing and job growth as a ‘central growth’ figure. In reality, this is the absolute minimum level of growth that should be planned for and should be identified as the low growth scenario within the topic paper.

The EHEU dismisses the higher growth scenario, principally on the basis that it is considered that the standard method level of growth is considered to be the ‘most likely’ growth scenario. This is not considered to be a justified or sound basis for setting the growth targets, which should be plan and evidence base led.

Paragraph 39 ID: 61-039-20190315 of the NPPG is clear that establishing the overall housing need should be conducted using the standard methodology unless specific circumstances justify an alternative. As evidenced by extensive research, over the recent years the level of job growth within the Greater Cambridge Area has been substantially higher than the Adopted Local Plan projections In this regard, it is considered that within Greater Cambridge there is a compelling case that the level of growth should be higher than the minimum level of growth as proposed using the Central level of growth or standard method housing and job figures.

The arguments and evidence for ambitious growth targets for Cambridge have been set out in a multitude of high-profile studies, plans, and government statements, which are set out below.
Cambridgeshire and Peterborough Independent Economic Review

The Cambridgeshire and Peterborough Independent Economic Review September 2018 (CPIER) is referenced in detail within the evidence based documents to support the emerging Local Plan. The CPIER report sought to develop an authoritative evidence base on the economic performance and potential of Cambridgeshire and Peterborough and informed choices on policy priorities and strategic investment. Regarding employment and housing the report sets out:
‘we have reached the clear conclusion that recent employment growth rates have been rather stronger than indicated by official figures, and we believe that the area can continue to deliver rapid growth with the right support’ … ‘growth in employment has not been matched by corresponding house-building, or developments in infrastructure’.

Further to the above, it is explained that:

‘success here is of national significance... but it will only be attained if there is more ambition with regard to the development of new housing, and a careful prioritisation of infrastructure projects’.

The CPIER report is clear that house building has for the last 30 years not kept pace with the level of job growth. This in turn has resulted in a substantial rise of house prices within Cambridge, with demand vastly outstripping supply, which in turn has created substantial affordability issues.

This data is strengthened by further data for example as set out in the Housing Key Facts, evidence based document published by Cambridge City Council (2025). This sets out that the current ratio of medium house price to medium income is 8.8 in Cambridge, which is above the national average of 7.7. For the lowest income quartile, this figure rises to 11.5, putting the city well above national affordability standards. This is further compounded by average rental prices, which are now on average £1,774 per month (based on 2025 ONS Housing Prices for Cambridge), which leaves little scope for professionals and workers renting to save money to get onto the housing ladder. Boosting housing supply in and around the City is therefore critical to addressing this acute housing shortfall.

Clearly basing proposed housing growth on employment projections and the standard method alone is too narrow an approach and more ambitious aspirational targets should be set. Particularly given the long history in Greater Cambridge of underestimating the level of employment growth in the past.
The Case for Cambridge

In March 2024 ‘The Case for Cambridge’ was published by the government, which set out ambitious plans for growth in Cambridge noting:
‘population growth is causing problems: pressure on house prices; high levels of congestion… a truly ambitious plan for growing the city and population will bring benefits, as opposed to frustrations, to residents’.

Two illustrative scenarios were put forward:
• Building 100,000 new homes by 2050 has the potential to add approximately £4.3 billion to the economy (between £2.1 billion and £6.4 billion with a central estimate of £4.3 billion). This in turn has the potential to translate in today’s terms into an annual increase of approximately £1.5 billion of additional receipts for the exchequer (income from taxes and other sources), which can be spent on public services.
• Building 150,000 new homes by 2050 has the potential to add approximately £6.4 billion to the economy (between £3.2 billion and £9.7 billion with a central estimate of £6.4 billion). This in turn has the potential to translate in today’s terms into an annual increase of approximately £2 billion of additional receipts for the exchequer (income from taxes and other sources), which can be spent on public services.

The current government subsequently reconfirmed its commitment to growth in Cambridge. In August 2024 Matthew Pennycook MP said the government was "ambitious for Cambridge" and that the city had been "constrained economically by the lack of housing". Again, the importance of setting bold aspirational targets for growth in Cambridge are highlighted at the highest levels of government. Whilst the current government has not provided a specific figure on housing growth, the government has set up a Development Corporation to accelerate growth in Greater Cambridge.

The emerging Local Plan covers a plan period to 2045. Table 3 of the plan sets out that the plan will deliver 52,032 dwellings between 2024 and 2045. If the housing growth in the Local Plan is continued on a pro rata basis using the 2,289 dwellings per annum for another 5 years, this would still only deliver 63,477 homes by 2050, which is still almost 37,000 dwellings lower than the government’s lower of the two Case for Cambridge growth scenarios. Whilst it is acknowledged that the aspiration to deliver 100,000 dwellings by 2050 is optimistic, there is considered to be a strong case to substantially increase the level of housing and employment growth above the standard method figures.

In this regard, the Mayor for Cambridgeshire and Peterborough Paul Bristow said in June 2026: ‘Our Local Growth Plan is intentionally the most ambitious in the country and delivering it means tackling infrastructure constraints we’ve put off for too long.’ As set out above, it is considered important for the emerging Local Plan to align with the Local Growth Plan. Further detail on the Local Growth plan is set out below.

Paragraphs 1.19 to 1.21 of the DLP acknowledge that the government has set up Cambridge Growth Company Development Corporation to accelerate growth, but then conclude that this Local Plan is only based upon the Council’s own evidence base for plan making. This is considered to provide a missed opportunity to accelerate growth in Greater Cambridge in the short term, prior to the Development Corporation having planning powers.
Cambridgeshire Local Growth Plan

In October 2025 the Greater Cambridgeshire & Peterborough Combined Authority Board approved the Local Cambridgeshire Growth Plan. This growth plan was heavily informed by the CPIER Report and this plan includes three growth scenarios:
• Baseline growth, or ‘business as usual’ would see the size of the economy grow to £42.5bn by 2050 - an annual growth rate of 1.2%.
• Doubling our Economy: our core scenario - would see the economy double in size by 2050 to £62.3bn GVA.
• Aspirational Growth: our growth ambition is to see the economy triple in size by 2050 to £97.1bn GVA, unlocking an economic powerhouse


It is also noted that:
‘these growth scenarios have undergone rigorous modelling and can be deliverable by 2050 with the right levels of support and investment’.

Page 155 of the Cambridgeshire Growth Plan is also clear that, to support a doubling of the economy by 2050, this would require a minimum of 214,760 dwellings to be delivered in the County during this timetable. Whilst the Local Growth Plan does not define a District by District breakdown of housing figures, it is clear that Greater Cambridge, as the focus for growth within the County, should be responsible for a substantial proportion of this growth. On a pro-rata basis, if the 214,760 dwellings were delivered equally between the six local authority areas in Cambridgeshire and Peterborough, this would result in Greater Cambridge having a requirement to deliver a minimum of 71,586 dwellings between now and 2050. In reality, accounting for Cambridge being the International Life-Science and employment driver for the County, in accordance with the government’s Case for Cambridge, the growth within the Cambridge City and South Cambridgeshire administrative areas would be expected to be substantially higher.

As set out above, as part of the reforms to the current planning system, the Greater Cambridgeshire and Peterborough Combined Authority will have to produce a Spatial Development Strategy for their area which will build on the Local Growth Plan and will include geographical and land-use designations. The mayor has committed to producing a spatial development strategy as a priority and it is anticipated this will be in place in 2028.

Paragraph 25 of the NPPF is clear that strategic policy making authorities should collaborate to identify strategic matters, which they need to address in their plans. They should engage with elected Mayors and Combined Authorities. Paragraph 26 of the NPPF then goes on to state that effective and ongoing joint working between strategic plan-making authorities and relevant bodies is integral to the production of a positively prepared and joint strategy.

In accordance with the requirements of paragraphs 25 and 26 of the NPPF, it is critical that the emerging Local Plan is aligned to the Cambridgeshire Local Growth Plan (2025) and the emerging Spatial Development Plan for Cambridgeshire. As a starting point, this should ensure that housing and employment growth is substantially increased to align with the objectives of the Cambridgeshire Local Growth Plan.

Conclusion on Policy SJ/H – Homes and Jobs and Amendments Required

Having regard to the clear growth aspirations set out both by the government and the Cambridgeshire Local Growth Plan, it is considered that the emerging Local Plan and Policy SJ/H needs to be revisited to provide a higher level of growth. A higher level of growth would align with both the governments and Mayors Vision for growth within the area and not providing this assessment is a current flaw of the plan and in turns results in the current plan not being positively prepared.

As set out above, delivery of growth in Greater Cambridge is of national significance. In the past, employment growth rates have been stronger than official figures and have outstripped delivery of housebuilding and infrastructure. The government has confirmed its continued support for high levels of growth in Greater Cambridge. This ambitious level of growth is also supported by the Local Growth Plan and will likely be reflected in the Spatial Development Strategy.

Based on this evidence, it is considered that the levels of job and housing growth targeted are not justified and are not an appropriate strategy taking into account the reasonable alternatives. A far more ambitious level of job and housing growth should be planned for. As it stands, Policy S/JH is unsound and requires amendment.

It is recommended that in order to be sound that the higher growth scenario as set out in the development strategy topic paper is followed, which is considered to be a more appropriate strategy for growth. This would require part 1 of Policy S/JH to be amended to replace the requirement to deliver 73,000 additional jobs with a requirement to deliver 90,936 jobs over the plan period and to replace the requirement to deliver a minimum of 48,069 dwellings, with a requirement to deliver a minimum of 59,409 dwellings over the plan period. For ease of reference the proposed amendments to the policy are set out below in the amendment section.

The following re-wording of Policy S/DS is suggested, with amendments highlighted in bold:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
a) Within the Cambridge Area
b) On the outer edge of Cambridge
c) At an expanded Cambourne
d) At other new settlements
e) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres.

These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy

This representation has been prepared on behalf of PfP and should be viewed in conjunction with our full response, as set out on the attached cover letter.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:
‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

Policy S/DS: Development strategy sets out the proposed strategy for the pattern, scale, and design quality of places created in Greater Cambridge, for the plan period to 2045 and beyond. This is one of the key strategic policies within the plan. The policy is set out in different parts. Part 1 of the policy states the following:

Policy S/DS: Development Strategy, sets out that the need for jobs and homes will be met in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a) Within the Cambridge Area
b) On the outer edge of Cambridge
c) At an expanded Cambourne
d) At other new settlements
e) In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres
…
Part 1 of Policy S/DS and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well-connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over-simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio-Medical Campus.

Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the reopening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of East West Rail and the Cambridgeshire Local Growth Plan (2025), which refers to the proposal to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket), which will include a new station at Cambridge East. This could include also include the provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, and Papworth Everard. As part of this re- assessment the reference to schemes of up to 30 dwellings being delivered in Minor Rural Service Centres, should also be removed from the policy.

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres.

These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

This response should be reviewed in conjunction with our full consultation response, which is attached.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over-simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio-Medical Campus.
Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the reopening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of East West Rail and the Cambridgeshire Local Growth Plan (2025), which refers to the proposal to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket), which will include a new station at Cambridge East. This could include also include the provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, and Papworth Everard. As part of this re- assessment the reference to schemes of up to 30 dwellings being delivered in Minor Rural Service Centres, should also be removed from the policy.

Add Proposed Additional Allocation

Land to the north and west of Wilbraham Road, Fulbourn - an allocation for a residential led mixed use development, including more than 2,500 homes (delivering 2,500 homes in the plan period, employment provision, a local centre, new education facilities and open space.

As a minimum for reasons explained above, the land north and west of Wilbraham Road, Fulbourn should be allocated as a reserve site.

This response has been prepared on behalf of PfP and should be read in conjunction with our full statement, attached.

Part 2 of Policy S/DS sets out that the vast majority of growth will be met via the following 3 new allocations, to supplement the existing allocations in the Adopted Local Plans:
• Cambridge East (Marshalls Airport) – allocated for approximately 8,000 dwellings (3,950 homes to delivered in the plan period) and 20,000m2 employment space
• Cambourne North – allocated for approximately 13,000 dwellings (delivering 2,720 homes within the plan period and 108,00m2 employment space
• Grange Farm Little Abington – allocated for approximately 4,500 dwellings (2,550 homes in the plan period) and 35,000m2 of employment space

This places a very high level reliance on the delivery of growth across only three sites, all of which are 4,500 dwellings or larger in size and all of which are predicated on significant infrastructure improvements. Since the publication of the Regulation 18 consultation, Cambridge North-East allocation has been amended to reduce the number of proposed new dwellings to 580 dwellings. However, rather than replace this allocation with new allocations, which would assist in reducing the reliance on the above 3 sites, the reduction in Cambridge North-East has resulted in a smaller housing buffer being provided. For reasons explained in this section of this report, this approach results in substantial concerns regarding the likelihood of housing delivery being delayed, which is likely to result in insufficient housing being delivered across the plan period.

PfP does not object to strategic-scale development or the allocation of larger sites. The concern is the degree of reliance placed upon a small number of strategic locations whose delivery is contingent upon major infrastructure interventions before substantial housing can come forward. By contrast, Land north and west of Wilbraham Road is capable of contributing to housing delivery during the early years of the Plan period and is not dependent upon the prior delivery of a new railway station or other major infrastructure. Whilst additional infrastructure, including a future station, would provide significant long-term benefits and support the Site’s full strategic potential, early phases of development are capable of coming forward in advance of such interventions. The allocation would therefore broaden the portfolio of strategic opportunities, increase choice and competition for market land and improve the flexibility and resilience of the overall strategy.

Table 1 of the Local Plan sets out that the current supply is 38,378 dwellings, with a further 9,691 dwellings required between 2024-2045 to meet the required need.

Table 3 of the DLP sets out that the Council has identified sites to deliver a further 13,654 homes over the plan period. 9,220 of the new dwellings, (which represents the majority of the 13,654 dwellings) will be met via 3 new urban extensions/new settlements at Cambridge East (Marshalls Airport Allocated under Policy S/CE), Cambourne North (Allocated under Policy S/CBN), and Grange Farm, Little Abington (Allocated under policy S/GF). The plan provides for an 8.2% buffer in housing delivery against the standard method. Accounting for the high reliance on the delivery of growth via only 3 sites, all of which have complicated infrastructure constraints it is considered that a buffer nearer to 20% would be preferable and would assist with providing a robust plan.

Based on the housing trajectory set out in the plan, it is apparent that 2025-2026 had a particularly low level of housing completions. This is concerning, particularly given that the early years of the plan are reliant almost solely on existing allocations to deliver growth. The housing trajectory states that upon adoption of the plan there will be a 5.47 housing land supply. However, this is based on the Liverpool method to assessing housing land supply, which is not the preferred method by government. Paragraph 68-031 of the PPG is clear that the preferred method for assessing land supply is the Sedgefield approach, which requires any backlog to be delivered within the following five years. This is to ensure that any backlog in supply is addressed early and not pushed back to later in the plan period. Using the Sedgefield approach, the housing land supply falls to 5.03 years. The trajectory also sets out that in the year of 2029/2030 annual completions will be almost 4,000 dwellings, which is more than a 1,000 units higher than all of the other (20 years) within the plan period. This delivery figure for the year of 2029-2030, appears to be highly optimistic and appears to have been increased with the purpose of ensuring that a 5 year housing land supply can be maintained during the early years of the plan. The housing delivery rates for a number of the strategic sites, including Waterbeach, Northstowe and Bourn Airfield are not considered to be realistic in year 2029-2030.

Accounting for the reliance of the emerging Local Plan on a limited number new settlements and urban extensions (of 4,500 dwellings and larger in size), there is a good prospect that the 5 year housing land supply will drop below 5 years. Figure 8 of the DLP shows the housing trajectory and it is clear that as a result of the vast majority of new growth being planned for within new settlements/urban extensions of more than 4,500 dwellings in size, there is very little growth from new allocations within the early years of the plan period.

This does not align with the NPPF’s objectives to significantly boost housing land supply and it has also resulted in the Shared Planning Service advocating the use of the Liverpool approach. This is not justified, particularly given that a large quantum of growth in the emerging Local Plan is made up of existing allocations. This should be addressed by the allocation of additional deliverable sites, such as land to the north and west of Wilbraham Road, Fulbourn, which can provide a very substantial contribution to housing supply but it can also provide choice and competition for market land, in a location that is not currently allocated for growth. As an absolute minimum consideration should be given to provision for reserve sites, which are capable of coming forward quickly at such time that the 5-year housing land supply drops below 5 years. Land to the north and west of Wilbraham Road, Fulbourn would be a logical site for a reserve site.

Further detail on the potential infrastructure and delivery constraints associated with the major new allocations are set out as follows:

Cambridge East

Policy S/CE: Cambridge East is a mixed-use development including 8,000 dwellings at Marshalls Airport. The land at Marshalls Airport was released from the Green Belt and safeguarded for development within the Cambridge Area Action Plan, which was adopted back in 2008, as a major new urban extension at Cambridge East. Since the publication of the Area Action Plan, schemes at Marleigh and Land north of Cherry Hinton have obtained consent and are currently being built out. However, some 17 years after the land was removed from the Green Belt, the development of the airport is still predicated on the relocation of Marshalls Airport to a new location.

Marshall announced in October 2025 that the business will not be moving to Cranfield but that the company is still committed to moving its aerospace business from its Cambridge Airport base by 2030 (with development anticipated to start in 2032). To support this, the site has recently been sold to Homes England and Hill Group, to bring forward development on the airport. Notwithstanding this aspiration, there is still no certainty that the airport will move within these predicted timescales, particularly given that an alternative site to relocate to has not yet been secured. As a result, development at Cambridge East could be significantly delayed which could result in limited or no housing delivery for a number of years, particularly within the first 15 years of the plan period. In accordance with paragraph 78 of the NPPF, it is considered critical that additional allocations are included in the plan to boost supply within the first 15 years of the plan. This will assist in the Shared Planning Service maintaining a 5 year housing land supply.
Grange Farm, Little Abington

The delivery of 4,500 dwellings at Grange Farm is predicated to an extent on the delivery of the Cambridge South-East Rapid Busway. The Cambridge South-East Rapid Busway is subject to an up and coming Transport for Works Order Public Inquiry and is also reliant on further funding to secure its delivery. Without the delivery of the busway the sustainability credentials of Grange Farm will be substantially reduced and it is questionable whether this is the most appropriate location for growth when considered against the alternatives.

Cambourne North

Policy S/CBN: Cambourne North sets out the proposed approach to the further expansion of Cambourne, taking account of the significant planned improvements to public transport in this area. The new settlement would include approximately 13,000 homes, 108,000 square metres of employment floorspace, with a range of supporting services and facilities.

The delivery of Cambourne North is predicated on the delivery of a new train line and a new train station as part of East-West Rail. The second and third stages of East West Rail, from Oxford through to Bedford and Bedford to Cambridge are still in planning & feasibility stages, and are dependent on final government funding and approval.  Stage 1 of East-West Rail is currently under construction and services are due to commence between Oxford and Milton Keynes in 2026. Stage 2 will then extend services to Bedford as part of upgrades to the Marston Vale line by 2030. Accounting for the delays to stage 1 of East-West Rail, completion of the upgrades in stage 2 to Bedford by 2030 is considered to be optimistic and it is likely to be delayed. Stage 3, which is between Bedford and Cambridge, has no set timetable for construction works to commence or to be completed and it will be subject to a Development Consent Order. The Bedford to Cambridge stretch of East West Rail requires provision for a new rail line and is likely to be the most costly and complicated stretch of East West Rail to deliver. It is considered very unlikely that this stretch of East-West Rail will be delivered until the late 2030s at the earliest and therefore it is very unlikely that land to the north of Cambourne will be deliverable in the next 15 years at least.

As set out in the Cambourne Growth-Transport Vision and Principles Evidence Base Document, the residential growth in Cambourne North is situated to the north side of the railway. It is also proposed to build 3 road bridges and 2 active travel bridges across the new railway and A428 to connect to Cambourne. This major infrastructure will be complicated to deliver and it is not feasible for Cambourne North to be delivered until such time as the new rail line and station have been completed. The

Spatial Framework Strategy, prepared as an evidence based document to support the Local Plan, suggests that the First New Neighbourhood will be delivered between 2035–2040, with East-West Rail Station also opening in the same period. Accounting for the substantial uncertainty and major infrastructure required, it is plausible that delivery of the site could slip into the 2040s and the number of dwellings to be delivered as part of this plan period will be very limited. In this regard, the proposed 2,550 dwellings to be delivered in Cambourne North within this plan period is considered to be optimistic.

In support of the Regulation 19 consultation, an updated Cambourne North Spatial Framework has been published. This sets out that an Outline application could be submitted in 2028+. 2028 for submission of the Outline application is considered to be unrealistic accounting for the above constraints. It is not considered that an outline application could be submitted, until such time that there is certainty on the exact location and delivery of the rail line, which is not going to be clear for a number of years.

The lack of certainty regarding the delivery of Cambourne North, further strengthens arguments as set out above that additional strategic sites such as land to the north and west of Wilbraham Road, Fulbourn should be allocated to boost housing supply and safeguard against the delay to delivery of the proposed allocated sites.

Overall, it is clear that allocation of land to the north and west of Wilbraham Road, Fulbourn will provide a number of benefits in terms of boosting housing supply, providing additional choice and competition of allocated sites to safeguard against slow delivery and to ensure that development is directed to the most sustainable locations. Its allocation is required in order for the plan to be positively prepared, justified, and effective having regard to the tests of soundness as set out within the NPPF.

The additional adjoining land shown on Figure 2 further strengthens the case for a comprehensive strategic allocation. It provides greater flexibility in refining the allocation boundary, distributing development and green infrastructure, coordinating access and movement and establishing a durable western edge. Its precise role should be established through proportionate technical assessment and the preparation of the Site-specific allocation policy.
Proposed Amendment to Policy S/DS

In order to be justified, positively prepared and in accordance with national policy it is critical that Policy S/DS is amended to include additional allocations. This should include land to the north and west of Wilbraham Road, Fulbourn. The following additional wording is proposed to part c of the policy that relates to Cambourne, which is highlighted in bold and italics:

Policy I/SI relates to Safeguarding Important Infrastructure. Part 1 of the policy states that land subject to safeguarding directions, as identified on the Policies Map, will be subject to consultation by the local planning authority with the relevant body. It states that planning permission will not be granted for development that would prejudice the construction or effective operation of the following transport schemes:
a) Proposals in the A428 Black Cat to Caxton Gibbet Improvement Scheme safeguarded area, which will require consultation with National Highways;
b) Proposals in the East West Rail scheme safeguarded area, which will require consultation with the East West Rail Company

Since the Regulation 18 stage, the proposals map for Fulbourn has been updated to identify part of the land under the control of PfP as a Safeguarded Area for important infrastructure. This relates to the area immediately to the north of the railway line, which is a safeguarded corridor for East- West Rail. In the consultation held in May- June 2026, East- West Rail identified land on the north side of the rail line at Fulbourn as a potential location for a train care centre.

PfP has no objection in principle to the proposed Train Care Centre, provided that its location and design do not prejudice the future development of Land north and west of Wilbraham Road, Fulbourn. As the East West Rail proposals continue to evolve, it would be premature to conclude that the safeguarding area presently shown is definitive or sufficient. The extent of land required should remain under review and be confirmed through the Proposed Submission Policies Map and the emerging East West Rail Development Consent Order process. Any subsequent change should be reflected in the Policies Map and coordinated with the Site allocation, station opportunity, railway crossings, access and active-travel requirements.