Greater Cambridge Local Plan: Proposed Submission

Policy S/JH should be entirely re-written to reflect a true ‘step change’ in economic circumstances with an appropriate job creation figure at Part 1a). Even if Part 1a) remains unchanged, these modest job growth aspirations must be matched by commensurate housing growth in order to represent sustainable development. As such, Part 1b) would need updating to reflect a housing requirement figure which is substantially uplifted to address this.

The implications are that the draft GCLP would need to identify additional allocations to meet the actual housing needs of Greater Cambridge.

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When read alongside SmithsonHill’s objections to Policy S/JH and the need to ensure that sustainable patterns of growth are achieved, Policy S/DS should be amended to allocate additional land in the Rural Southern Cluster. We consider that this should include the Site on the basis that it closely aligns with the proposed spatial strategy as it stands, is well related to existing public transport and growth (for example the Wellcome Genome Campus expansion and research park at Great Chesterford), and as demonstrated in our representations on the HELAA in Section 8, does not have any insurmountable technical issues which preclude development.

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SmithsonHill considers that allocating the southern part of the Site would enable a comprehensive approach across both parcels, with the northern parcel supporting a sustainable travel hub and the southern parcel delivering housing-led mixed-use development

A Sustainable Transport Gateway in this location could create a true gateway to the Rural Southern Cluster; a potential place where people arrive by rail, then the gateway travel hub facilitates onwards travel with buses or shuttles to CSET, safe onward pedestrian connections and bike hire to the Wellcome Campus, the Hinxton development, Granta Park, Babraham Research Campus all via sustainable travel options. There is also potential for it to accommodate an expanded route for the CSET that takes in Wellcome Genome Campus and Whittlesford Parkway Station, among other places.

The approach set out above would encourage development in line with central government’s ambitions to unlock growth around key commuter hubs, alongside meeting the Councils’ vision to unlock sustainable growth within the Rural Southern Cluster. A Sustainable Transport Gateway could provide a point of arrival by rail and onward distribution by shuttle, bus, cycle and walking routes to Wellcome, Hinxton, Granta Park and Babraham.

Absent an allocation, the Councils are likely to face proposals relying on the 2026 NPPF decision-making framework. A plan-led allocation would allow those benefits to be captured strategically and on the Councils’ terms.

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The below changes need to be made to the housing trajectory:

1 A significantly increased buffer between the housing requirement (Policy S/JH) and stated supply needs to be incorporated to ensure delivery and to ensure the draft GCLP is positively prepared and effective.
2 More allocations must be made in the early years of the plan period to ensure that on adoption, when a 5YHLS cannot include a windfall allowance, the GCSP Service has enough sites to demonstrate a 5YHLS on adoption.
3 More realistic lead-in time and build-out rate assumptions need to be utilised to ensure there is no overconfidence by the GCSP Service with the “strength of the market” in light of both the blanket affordable housing policy across the whole area which will impact viability and the wider decline in market absorption rates slowing down market housing delivery.
4 To address the above, more sites for residential development will need to be allocated and included in this trajectory.

This comment relates to Appendix D Housing Trajectory and 5YHLS

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If the Viability Report 2026 is not revisited, specifically with regards to Policy H/AH, in light of the issues raised in this representation in relation to the Viability Report 2026, the policy needs to allow for some optionality in circumstances where the Viability Report 2026 has not provided a realistic outcome, especially for strategic sites.

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The market housing requirements at Table 8 should be recast as ‘targets’, and the wording of the policy should include the text, or a version of the text, at HO8(3). This would ensure that the policy is in line with the NDMP that would apply to development proposals in any eventuality.

SmithsonHill does not necessarily object to this policy and do not raise concerns relating to its soundness against the NPPF (2024). However, noting that decision-making policies in NPPF (2026) would be relevant straight away upon adoption of the plan, Policy H/HM should be brought in line with NPPF (2026) decision-making policy HO8(3) which states:

“Where development proposals meet or exceed up-to-date development plan requirements for the proportion and mix of affordable housing tenures, including the minimum proportion of Social Rent properties, a flexible approach should be taken to the application of any development plan requirements relating to the number of bedrooms provided in market homes, taking into account prevailing market conditions.”

It is noted that the HELAA assessment for the emerging allocation at Grange Farm (HELAA Site ID 59401) also has an Overall Suitability RAG Score of Red, Available RAG of Green and Achievability RAG of Green. This shows that if the Site were to be pursued as an emerging allocation, it would do so with the same concluding assessment as Grange Farm, which is an emerging allocation. As set out extensively elsewhere in our representations, more housing allocations are needed to make this plan sound, and on the basis of the analysis here, the Site should be one of them.

Notwithstanding, the HELAA is overly heavy handed in its assessment and is not in all cases correctly applying its own methodology, it cannot be considered accurate nor robust. Smithson Hill consider that policies informed by this evidence-based document cannot be justified as per NPPF paragraph 36(b) as the strategy of the draft GCLP is not based on accurate, and therefore not proportionate, evidence. Furthermore, it means the HELAA is not in accordance with NPPF paragraph 32 which states local plan preparation should be underpinned by relevant and up to-date evidence. This cannot be the case when the evidence base itself is inaccurate.

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See Representation ID: 213531

If the Viability Report 2026 is not revisited, specifically with regards to Policy H/AH, in light of the issues raised in this representation in relation to the Viability Report 2026, the policy needs to allow for some optionality in circumstances where the Viability Report 2026 has not provided a realistic outcome, especially for strategic sites.

In Hill’s response to the Greater Cambridge CIL consultation (attached as Appendix 2), significant concerns were identified with the viability evidence presented to support the CIL charging schedules and the same observations are made of the VR. The CIL sales values that have been tested in the VR are not reflective of the sales values within Greater Cambridge. Lichfields’ analysis found that the vast majority of scenarios presented in the viability evidence supporting the CIL charging schedule were likely to be unviable once the appropriate sales rates had been applied and affordable housing policy taken into account. This is the case in the VR.

It is disappointing to see, in light of the above, that the VR underpinning the draft GCLP has continued to present a highly optimistic and generalised approach to assessing viability across the varied sales value areas in Greater Cambridge.

The VR splits Greater Cambridge into ‘zones’ for the purposes of assessing viability. The VR states it has “undertaken extensive market research, stakeholder consultation and consultation with the Council to finalise these housing value zones due to the diverse housing market”. The value zones are set out as follows:

1. Higher value zone: between £6,300 and £8,300 per sqm – an average of £7,250 per sqm overall (£7,600 per sqm for flats and £6,785 per sqm for houses).
This relates to the highest value parts of Cambridge City, where it is assumed that the majority of residential development will comprise flatted schemes, a number of which will be on brownfield land, leading to increased abnormalities.

2. Mid value zone: between £5,800 and £7,600 per sqm – an average of £6,450 per sqm overall (£6,675 per sqm for flats and £6,150 per sqm for houses).
This related to the remaining wards within Cambridge City, and most of the directly adjoining wards within South Cambridgeshire, where development is anticipated to
comprise both flatted schemes and conventional houses. Given that this predominantly comprises land in the green belt, affordable housing requirements in these locations
will be set at 50%.

3. Low value zone: between £5,000 and £6,000 per sqm – an average of £5,450 per sqm overall (£5,745 per sqm for flats and £5,255 per sqm for houses).
This relates to the rest of Cambridge, where new settlements will come forward and proposed research campus expansion is anticipated. The strategic allocations in the low value zone are likely to face the largest up-front infrastructure costs owing to their lack of connectivity to existing built form and amenity. Development in these locations is likely to be lower density homes, with a smaller quantum of flats.

It is notable that across all value zones, the assumed value of houses is below the overall average (both median and mean) new build achieved £/sqm house values across Greater Cambridge. Considering table 4.12 of the Residential Property Market Report (Appendix 3 of the VR) against the assumed sales values, it is clear that the achieved new build values for houses are significantly lower than the assumed sales values of the VR. Such in-built optimism does not appear to be justified in the VR and it is therefore not clear what the basis for such an uplift is.

Inflating assumed sales values for houses is likely to have the most significant effect on the viability of sites in the lower value zones, since these are most likely to deliver houses over flats. They are also, by nature, the areas where values are lowest and viability is most stretched. As raised by The Hill Group in its representations to the Greater Cambridge CIL consultation, the residential sales values in the rural areas are likely to lead to development
becoming unviable once the costs associated with the proposed levels of affordable housing, CIL, and in-kind infrastructure provision are included.

SmithsonHill does not consider that the VR has appropriately considered the cost of s106 infrastructure alongside CIL for strategic sites (for a residential-led development this is defined in the NPPF 2026 as at least 1,500 dwellings). Whilst it is acknowledged that the VR does consider affordable housing and CIL, there is a significant lack of specificity around the infrastructure costs associated with proposed allocations. Clearly, for strategic sites that are more directly integrated with the delivery of infrastructure, infrastructure costs will be significantly higher than smaller sites. A ‘standard’ s106 cost-per-dwelling rate of £45,500 is applied to each development typology tested, regardless of the scale of
development and site-specific infrastructure needed to make it acceptable in planning terms. This is despite p.91 of the VR acknowledging “that the Strategic Sites will bear a greater burden of the IDP costs than the other typologies, as they will likely have greater strategic infrastructure included.” For a development strategy containing such a significant quantum of strategic proposals, this is not an adequate assessment of effects.

By failing to consider site-specific infrastructure delivery costs in its assessment of site viability, the Councils are unable to effectively demonstrate whether the proposed affordable housing requirement will be achievable alongside other requirements. This is particularly relevant when considered alongside the points made above in relation to the inflation of residential sales values for houses and the effect this will have on viability in lower value areas in particular.

Please consider the attached document alongside the Representation ID: 213531 which is referenced in the Policy H-AH - SmithsonHill.pdf

When read alongside SmithsonHill’s objections to Policy S/JH and the need to ensure that sustainable patterns of growth are achieved, Policy S/DS should be amended to allocate additional land in the Rural Southern Cluster. We consider that this should include the Site on the basis that it closely aligns with the proposed spatial strategy as it stands, is well related to existing public transport and growth (for example the Wellcome Genome Campus expansion and research park at Great Chesterford), and as demonstrated in our representations on the HELAA in Section 8, does not have any insurmountable technical issues which preclude development.

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It is considered that the draft GCLP needs to allocate more sites for residential development in order to be found sound. This is to bring planned levels of employment growth in line with the housing requirements and support a housing trajectory in which needs are met at the earliest opportunity. HELAA Site 200765 is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operation sustainable transportation, Whittlesford Parkway Station. It can also come forward in tandem with other large-scale developments, including Grange Farm should that be concluded to be justified.

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