Greater Cambridge Local Plan: Proposed Submission

Policy S/DS should be amended to recognise the role that sustainable small and medium-sized sites can play in supporting housing delivery alongside the major strategic allocations. Whilst the focus on Cambourne North and other strategic growth locations is supported, the Plan should allow for additional growth in sustainable and well-connected locations where sites can be delivered independently of major infrastructure requirements. This would improve the resilience and flexibility of the housing trajectory, reduce reliance on a limited number of large strategic sites, and provide greater confidence that housing needs can be met throughout the plan period.

Our client remains supportive of the proposed development strategy, which principally seeks to direct strategic growth towards Cambridge, the edge of Cambridge and an expanded Cambourne. The proposed strategy recognises the significant opportunities presented by new sustainable transport connections and the potential for Cambourne North and the wider Cambourne area to accommodate significant growth. Our client supports this ambition.

However, the strategy should also recognise the important role that smaller and medium-sized sites can play in supporting housing delivery, particularly where such sites are located in sustainable and well-connected locations and can come forward independently of the delivery and build-out trajectories of the major strategic allocations.

The Regulation 19 version of Policy S/DS identifies approximately 13,000 dwellings at Cambourne North, of which approximately 2,550 dwellings are anticipated to be delivered within the plan period. In addition, approximately 4,500 dwellings are proposed at land adjacent to the A11 and A1307 at Grange Farm, of which approximately 2,550 dwellings are anticipated within the plan period. The Plan therefore relies significantly on the delivery of large-scale strategic sites, with a substantial proportion of their overall capacity expected to come forward beyond 2045.

The Council's evidence recognises that strategic sites have long lead-in times and that their delivery is closely associated with the provision of infrastructure. In the case of Cambourne North in particular, delivery is closely linked to the proposed East West Rail station and associated transport infrastructure. The anticipated delivery of 2,550 dwellings within the plan period therefore represents a significant dependency within the housing trajectory.

In this strategic scale context, maintaining a diverse and resilient supply of housing sites is important. The inclusion of additional sustainable sites would not undermine the primary role of Cambourne North or the wider development strategy. Rather, it would provide greater flexibility within the housing trajectory and reduce reliance upon a limited number of large-scale developments and their associated infrastructure and phasing requirements.

MMSL's preferred approach is for Papworth South to come forward as a sustainable and logical extension to Papworth Everard, capable of making a meaningful contribution to housing delivery within the plan period. Unlike the major strategic allocations, the site can come forward independently and does not rely upon the delivery of East West Rail, the Cambourne North strategic infrastructure or the comprehensive build-out of a major new settlement before development can commence.

The Regulation 19 consultation document identifies a housing need of 48,069 dwellings and a total supply of 52,032 dwellings, providing 8.2% headroom. Whilst this provides a quantitative margin, the level of headroom should not be considered in isolation from the deliverability, phasing and infrastructure dependencies associated with the sites comprising that supply. Additional deliverable opportunities in sustainable locations would provide greater resilience and flexibility within the housing trajectory and increase confidence that the identified housing requirement can be met throughout the plan period.

The allocation of Papworth South would therefore provide an opportunity to bring forward additional housing through a site which can be delivered independently and which can contribute to the wider objectives of the Plan, including the provision of new homes, community facilities, active travel connections and sustainable transport links. These benefits can be realised within the plan period rather than being wholly dependent upon later phases of strategic growth.

We acknowledge the emphasis placed within the supporting text on the role of small sites in maintaining housing supply. However, the Plan should also recognise the role of sites which sit beneath the very large strategic allocations proposed. The policy should therefore allow appropriately located additional growth in sustainable and well-connected locations where this can support housing delivery, improve the resilience of the housing trajectory and complement, rather than undermine, the wider spatial strategy.

Accordingly, the Plan should be amended to provide greater flexibility for appropriately located sites which can contribute to housing delivery within the plan period, including the proposed allocation of Papworth South, providing additional choice and resilience in the housing land supply while maintaining the Plan's overall focus on sustainable locations and strategic growth.

Supports the ability to deliver development at varying scales across the hierarchy. Consider that the current approach, whereby indicative maximum capacities have been used to establish the extent of appropriate growth, is overly restrictive and doesn’t allow for individual sites to be duly considered on their merit. Whilst the hierarchy provides a useful strategic framework, development capacity should be informed by site-specific circumstances, sustainability credentials and development constraints rather than indicative numerical thresholds. In locations such as Papworth Everard, where accessibility and connectivity are likely to improve significantly from planned infrastructure, a flexible assessment of growth opportunities may be appropriate.

Support the flexibility within Part 2 , that development outside defined development extents may be acceptable where supported by other Plan policies. This avoids a blanket prohibition on development beyond settlement boundaries and allows proposals to be considered against the wider policy framework. However, criterion (d), which provides an exception where development is "supported by other policies of the Plan", is ambiguous. It is unclear which policies are intended to provide such support and whether this includes only policies that expressly promote development, or those enabling development subject to compliance with specified criteria. Greater clarity would assist applicants and decision-makers.

We support the principle of the monitoring policy and consider that ensuring delivery is being duly tracked is vital to maintaining a healthy supply of development. We do consider that a more proactive and resilient approach would be to identify a portfolio of suitable, available and deliverable reserve sites that have already been subject to assessment through the plan-making process. This would provide the Council with a clear mechanism to respond swiftly should delivery issues emerge, particularly in relation to larger strategic allocations where housing delivery is dependent upon major infrastructure investment, complex land assembly arrangements or extensive phasing programmes.

MMSL are supportive of the proposed allocation of Cambourne North as a strategic site (subject to the proposed boundary amendment detailed below). The proposed allocation, which is to a large degree reliant on the delivery of the East West Rail project and the Cambourne to Cambridge high quality public transport corridor, is substantial and will alleviate significant development pressures on Cambridge City and the surrounding Green Belt.
Whilst the policy is positively drafted regarding the delivery of development within the allocation itself, MMSL has concerns regarding the complexities associated with delivering development at this scale. Large strategic sites are inherently vulnerable to a range of economic, political, technical and environmental factors which may delay delivery despite the best efforts of those promoting them. This creates uncertainty where a significant proportion of the housing requirement is reliant upon a limited number of strategic allocations.
The NPPF is clear that the planning system should support the Government's objective of significantly boosting the supply of homes and ensure that a sufficient supply and mix of sites is available to meet housing requirements. Whilst strategic allocations such as Cambourne North will play an important role in meeting longer-term needs, the Plan should also support sites capable of accelerating housing delivery in the short term and maintaining delivery momentum whilst major infrastructure-led developments progress through their longer delivery programmes. A diverse portfolio of sites provides resilience within the housing trajectory and helps reduce the risk of delays associated with reliance on a limited number of large-scale developments.
It is for these reasons that MMSL advocates the inclusion of sites such as Crow's Nest Farm, which can help address shorter-term delivery requirements whilst larger strategic proposals are progressing through infrastructure delivery and longer-term build-out programmes.MMSL has undertaken extensive technical work to demonstrate that land at Crow's Nest Farm is deliverable in the short term. The delivery of Crow's Nest Farm for housing-led mixed-use development would ensure that the existing community at Papworth Everard benefits from the opportunities associated with East West Rail and is not isolated from the wider economic and connectivity benefits that the project seeks to unlock, whilst retaining flexibility regarding the precise spatial relationship between the site and the wider Cambourne North allocation.
Whilst MMSL wishes to ensure that Papworth Everard benefits from the opportunities associated with East West Rail, it also recognises the importance of maintaining a meaningful and defensible strategic gap between Papworth Everard and Cambourne North. MMSL is concerned that the Regulation 19 allocation boundary extends unnecessarily close to Papworth Everard, reducing flexibility for the future evolution of the settlement and effectively ringfencing the settlement. The earlier Regulation 18 boundary provided a more balanced approach, maintaining separation whilst allowing opportunities for proportionate growth. As currently drafted, the Policies Map constrains the delivery of Crow's Nest Farm through both the extent of the Strategic Enhancement Area and the proximity of the Cambourne North allocation boundary. Papworth South presents an opportunity to strengthen connectivity between Papworth Everard and Cambourne North whilst maintaining a meaningful strategic gap between the two settlements. The site is uniquely positioned to facilitate movement between the existing and proposed communities, ensuring that the benefits of the East West Rail project and associated transport investment can be shared more widely.
The draft allocation is predicated upon a comprehensive transport strategy, including new access arrangements from the A1198, delivery of the Cambourne to Cambridge High Quality Public Transport Corridor (HQPT), new active travel connections and the provision of a Mobility Hub. The Council's own evidence identifies the Mobility Hub as a key component of the strategy, supporting early expansion of the HQPT corridor and improving connections between Cambourne North, Cambourne and Papworth Everard from the outset.
MMSL supports these transport objectives and has undertaken technical work demonstrating that there are no impediments to delivering the access arrangements and associated infrastructure required to support growth. Importantly, development at Crow's Nest Farm could assist in bringing forward elements of this infrastructure at an earlier stage, including the Mobility Hub and enhanced walking, cycling and public transport links, helping to establish sustainable travel patterns from first occupation and reducing reliance on the private car.
The site also provides an opportunity to deliver a more attractive and overlooked active travel connection between Papworth Everard and Cambourne North. Current indicative routes are largely aligned alongside highway corridors and have limited natural surveillance.By contrast, a route integrated into a residential-led development would benefit from active frontages and overlooking, creating a safer, more attractive connection.
The draft policy already recognises the importance of connectivity. Paragraph 13(e) confirms that the Strategic Enhancement Area may accommodate improved active travel and highway connections, whilst the Movement section seeks enhanced walking, cycling and public transport links to surrounding settlements, including the extension of the HQPT corridor towards Papworth Everard during the early phases of development. MMSL strongly supports these objectives and considers they would be significantly strengthened through the delivery of Papworth South, which is strategically positioned to improve connectivity between Papworth Everard and Cambourne North and can contribute positively to the wider movement, landscape and placemaking objectives of the allocation.
The supporting text to the policy positively recognises the importance of responding sensitively to neighbouring settlements and reflects the role of the landscape masterplan and associated buffers. MMSL considers that this could be strengthened through a more explicit reference to connectivity with nearby existing communities, ensuring that the benefits arising from the delivery of Cambourne North are shared more widely. In this respect, the Movement section of the policy is particularly welcomed, requiring enhanced walking and cycling connections to surrounding villages and the early extension of the Cambourne to Cambridge public transport corridor to Papworth Everard. These measures recognise the importance of connectivity between the two settlements. Crow's Nest Farm provides an opportunity to further strengthen these connections through the delivery of complementary movement and active travel infrastructure, whilst maintaining a meaningful physical separation between Papworth Everard and Cambourne North. This objective would be more readily achieved if the Cambourne North allocation boundary were amended to reflect the earlier Regulation 18 approach and maintain a stronger strategic gap between the settlements.
It is emphasised that our proposals do not seek to compete with the primacy of the Cambourne North expansion. The identified vision for Cambourne North is robust and coherent, but as the draft policy recognises, the overall success of the town will depend on physical integration and onward connectivity via railway to Cambridge and beyond. It is important for the emerging Local Plan to be resilient to wider economic factors that could challenge the delivery of the spatial strategy. Proportionate extensions to existing settlements like Papworth Everard present a sustainable alternative.

MMSL remain supportive of the principle of Policy H/AH seeking to optimise affordable housing delivery in Greater Cambridge, particularly given the acute affordability challenges faced. However, as currently drafted, Policy H/AH risks being overly rigid and insufficiently responsive to site-specific viability.
As per the Regulation 18 draft Local Plan, the draft policy proposes a minimum affordable housing requirement of 40% on major developments of 10 dwellings or more, unless otherwise specified through site specific allocation policies or within the Green Belt (with specific co-living considerations added). While the principle of a policy led approach to affordable housing delivery is supported, the imposition of a uniform minimum requirement risks failing to adequately reflect the diversity of site conditions, abnormal costs and market circumstances that can materially affect scheme viability. Although the policy allows for viability testing, the overall framing remains prescriptive, which may discourage development coming forward, particularly on marginal or constrained sites. It is suggested that a tiered approach to affordable housing provision could be considered to encourage SME delivery and improve flexibility where justified by site-specific circumstances.
The NPPF update published in August 2024 is supportive of the locally prescribed approach to tenure splits proposed by the policy, seeking for development plans to identify requirements for the proportion and mix of affordable housing tenures, including a minimum proportion of social rent, informed by local evidence. As such the proposed breakdown in Policy H/AH is in accordance with the revised Framework. Our only commentary would be that allowing some flexibility, through the use of, as the NPPF suggests, minimum social rent figures, may enable site specific considerations to more positively influence mix and respond to constraints.

MMSL supports the overarching objective of Policy H/HM to secure a balanced housing mix that responds to identified needs across Greater Cambridge, including the delivery of family housing, smaller homes and accommodation suitable for older people. The use of indicative housing mix requirements can provide a useful framework for delivering identified needs across the plan area. However, it is important that sufficient flexibility is retained to ensure schemes can respond appropriately to site-specific circumstances, changing market conditions and locally evidenced housing requirements. In this regard, MMSL welcomes the supporting text to Policy H/HM, which confirms that deviations from the prescribed housing mix will be permitted where an alternative mix is justified, having regard to factors including site context, character, build form, the nature of the proposed development, site-specific viability considerations, changes in local housing demand and the existing housing mix in the surrounding area. This flexibility is strongly supported and should be clearly embedded within the policy wording to ensure that development proposals can respond to evolving housing needs whilst continuing to deliver sustainable and viable schemes.

The principle of reducing reliance on private car travel and promoting sustainable, inclusive and well-connected development through a vision-led approach is strongly supported. The policy's emphasis on walkable neighbourhoods, high-quality walking, wheeling and cycling infrastructure, and integration with public and community transport is welcomed and aligns with the objectives for Papworth South, as explored in the site-specific representations. These objectives are also consistent with the NPPF, which promotes patterns of development that prioritise sustainable transport choices, reduce the need to travel by private car and support the creation of healthy, connected communities.
Of particular relevance is subsection (c), which requires the provision of new mobility hubs to enable interchange between different modes of sustainable transport. It is considered that the wording used to define mobility hubs should be expanded to encompass wider community and connectivity functions, thereby providing greater flexibility to respond to local circumstances. This would better reflect the role that such hubs can play not only in facilitating modal shift, but also in improving access to services, supporting social interaction and strengthening connectivity between existing and proposed communities.
Against this background, MMSL consider that draft Policy I/ST responds positively to the requirements of the updated NPPF, despite it being drafted prior to its recent publication. Indeed, MMSL endorses the intentions of this policy to deliver walkable developments that are well integrated with existing communities.
Similarly, MMSL welcomes the recognition that a range of public transport modes and their linkages with Mobility Hubs as part of a wider transport vision for an area. To this end, MMSL equally endorses draft Policy I/MH particularly given that the representations made to date in respect of its landholdings to the south of Papworth Everard have included provision for such infrastructure.

It is acknowledged that ‘Policy I/MH: Mobility Hub Facilities’ provides additional information and design requirements in connection to the delivery of Mobility Hub facilities. It is suggested that an additional criterion is added under part 2, i.e as clause (g) for the following lines to include accessibility of facilities:
“(g) they incorporate inclusive and step-free access between transport modes, appropriate lighting and natural surveillance”
This would strengthen the effectiveness of the policy, whilst also ensuring that the delivery of these mobility hubs are future-proofed and inclusive of wider population needs.
MMSL supports the role of travel hubs as strategic components of the sustainable transport network and considers them to be particularly important in the context of urban extensions, which are a key component of the Local Plan development strategy. Such developments are often delivered over long timescales and are typically located at the edge of existing settlements, increasing the risk of early car dependency if sustainable travel options are not available from the outset. Mobility hubs provide a critical mechanism to secure early and long-term integration with public and community transport, enable modal interchange, and mitigate cumulative transport impacts. The policy would be strengthened by explicitly recognising the importance of early delivery, phasing and long term adaptability of mobility hubs within town extensions, ensuring they function as foundational infrastructure rather than retrospective mitigation.

The policy identifies land that is subject to safeguarding directions, including the East West Rail scheme. MMSL are concerned with the extent of land safeguarded for East West Rail which is contained within the ownership boundary of Crow’s Nest Farm (Site Ref. 48096).
MMSL made extensive representations to the East West Rail non-statutory consultation in 2024, raising concerns regarding the extent of land proposed to be acquired through the Development Consent Order process. Further representations have subsequently been submitted to the statutory consultation process, continuing the constructive dialogue with East West Rail regarding the interface between the proposed railway infrastructure and the future development potential of the site. Our view is the extent of land safeguarded, and subsequently confirmed on the draft Proposals Map, has not been justified by EWR and extends northwards into Site Ref 208867, and so prejudices the site’s development potential. It is unclear why such an extensive tract of land is safeguarded beyond the proposed route of the railway. For the avoidance of doubt, MMSL strongly supports the principle of East West Rail as a catalyst to realising growth potential but land should be safeguarded in a proportionate and justified manner that does not sterilise the development potential of adjacent land.
MMSL appreciates the strategic importance of ensuring this key piece of infrastructure if delivered in a timely manner. As such, MMSL also endorses draft Policy I/SI. MMSL has confirmed through its representations that they are in open dialogue with East West Rail to ensure that its infrastructure needs are not prejudiced by development on its land.