Greater Cambridge Local Plan: Proposed Submission

A sound approach would reassess the hierarchy on a more connectivity-led basis, giving consistent and transparent weight to existing and planned sustainable transport, proximity to major employment concentrations and services shared between functionally related settlements.

Across these strategic priorities, the plan rightly identifies the importance of locating development so as to reduce the need to travel, providing homes close to jobs and services, supporting Greater Cambridge’s internationally important economy and reducing reliance on the private car. Those objectives are consistent with the December 2024 NPPF. Paragraphs 108-110 of the NPPF require transport issues to be considered from the earliest stages of plan-making; opportunities to promote walking, cycling and public transport to be identified and pursued; significant development to be focused on locations which are or can be made sustainable; and patterns of development to minimise the number and length of journeys required for employment and other purposes.

Those requirements are important in Greater Cambridge because the geography of economic activity is not confined to Cambridge City itself. The Rural Southern Cluster contains a concentration of nationally and internationally significant research and employment activity, including the Wellcome Genome Campus (directly adjacent to the Site), Granta Park and Babraham Research Campus. The draft Plan itself proposes
substantial further employment growth within this cluster through some of its proposed allocations. A sound spatial strategy therefore needs to consider not simply the conventional hierarchy of existing settlements, but the functional geography of homes, employment and transport infrastructure.

SmithsonHill recognises that plans will often seek to develop an understanding of their settlements and the associated hierarchy. For the draft GCLP this is based on the Development Strategy Topic Paper 2026 Appendix 18: Settlement Hierarchy Study Update 2025. It is clearly right that new homes should be directed towards settlements which can offer high levels of amenity. However, the settlement hierarchy is being applied too rigidly if it results in locations being discounted notwithstanding their relationship with major employment destinations and existing or planned sustainable transport infrastructure. In a rural area containing dispersed but substantial employment campuses, the sustainability of a location cannot sensibly be assessed solely by reference to the services contained within an individual village boundary. The relevant question is also how effectively that location connects residents to employment, services and wider transport networks.

The plan fails to realise the potential of existing transport hubs in Cambridge’s Rural Southern Cluster, particularly where they demonstrate potential for growth in line with national policy. For example, the plan could group villages with campuses and/or travel hubs such as existing train stations and areas which are proposed to benefit from enhanced transport links.

At present, the land around Whittlesford Parkway, whilst allocated for some development (albeit we have concerns around the achievability of what is proposed, see SmithsonHill’s response to Policy S/AMC/WHD), has significant further potential owing to its proximity and connectivity to both the Babraham and Wellcome Genome Campuses, as well as the frequent connections into Cambridge City and London.

In this context, the Councils’ settlement hierarchy methodology does not provide a sufficiently robust basis for determining the relative sustainability of rural settlements or the scale of growth that they should accommodate, particularly given the blunt nature of the
scoring mechanism, with wide variations in score within each tier hierarchy and overlaps in scores between tiers. The Settlement Hierarchy Study acknowledges that classification is ultimately a matter of judgement, but does not establish transparent thresholds or criteria explaining when and why that judgement should override the quantitative assessment. The result is a hierarchy which is difficult to reproduce or objectively interrogate, notwithstanding the significant consequences that classification has for the spatial distribution and scale of development.

This weakness is compounded by the way in which the methodology conceptualises rural sustainability. Most of the available score relates to services, facilities and employment associated with the settlement itself, with relatively little for connectivity (and strategic rail connections in particular that the Government in its NPPF 2026 has said are an inherent starting point for residential development). This is particularly important in the Rural Southern Cluster, where major employment destinations are dispersed between locations such as the Wellcome Genome Campus, Granta Park and Babraham Research Campus and where Whittlesford Parkway provides existing strategic rail connectivity.

National policy does not require rural settlements to operate as isolated, self-contained units and expressly recognises that development in one village may support services in another (see NPPF para 83). A sound spatial strategy should therefore be based on evidence that assesses how settlements function as part of wider networks of homes, employment, services and sustainable transport, rather than principally according to what happens to fall within an individual settlement.

There are also inconsistencies in how functional relationships are recognised. The hierarchy expressly allows some settlements, including Great Shelford/Stapleford and Histon/Impington, to be considered together. There is no equivalent transparent methodology for determining when other settlement relationships should be recognised.

These deficiencies have consequences because the hierarchy feeds directly into the assessment of the spatial strategy and reasonable alternatives. The Sustainability Appraisal records negative accessibility effects for a number of village and Rural Southern Cluster options because they are not close to a centre recognised by the hierarchy, notwithstanding that many of the same locations perform positively in relation to public transport and, in the Rural Southern Cluster, proximity to employment.

There is therefore a risk of circularity: a well-connected settlement is placed lower in the hierarchy because the methodology gives insufficient weight to its wider functional relationships, and development at that settlement is subsequently assessed less favourably because it is not close to a higher-order centre defined by that same hierarchy.

This undermines the ability of the evidence base to demonstrate that Policy S/DS represents an appropriate strategy, taking into account the reasonable alternatives and based on proportionate evidence.

A sound approach would reassess the hierarchy on a more connectivity-led basis, giving consistent and transparent weight to existing and planned sustainable transport, proximity to major employment concentrations and services shared between functionally related settlements.

This would recognise that some rural locations perform a materially different strategic function because they combine:
• proximity to major existing and expanding employment campuses;
• access to existing rail or other high-quality public transport;
• opportunities for enhanced active-travel connections;
• the ability to support improved public transport between employment destinations; and
• sufficient development potential to provide additional services and facilities as part of planned growth.

Such locations should not be treated in the same way as otherwise comparable rural settlements which lack those characteristics. This does not necessarily mean abandoning the settlement hierarchy but requires recognition of the functional relationships which the Councils' own economic and transport strategies are seeking to strengthen.

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 dGCLP (Reg 19) 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

Please see attached document. The response includes tables, images and formatting that cannot be supported by this text box.

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 dGCLP (Reg 19) 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

Please see attached document. The response includes tables, images and formatting that cannot be supported by this text box.

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 dGCLP (Reg 19) 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

Please see attached document. The response includes tables, images and formatting that cannot be supported by this text box.

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 dGCLP (Reg 19) 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

Please see attached document. The response includes tables, images and formatting that cannot be supported by this text box.

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 dGCLP (Reg 19) 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

Please see attached document. The response includes tables, images and formatting that cannot be supported by this text box.

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.

Please see attached document. The response includes tables, images and formatting that cannot be supported by this text box.