Greater Cambridge Local Plan: Proposed Submission

Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 100 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

Please refer to the submission attachments for the correctly formatted full submission, which includes figures and tables.

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of Cala Management Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 Our client has an interest at land west of Water Lane, Melbourn, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details on site context and Cala Management Ltd are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity.

1.2 Regulation 19 Consultation
1.2.1 The Regulation 19 Consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge to submit the emerging Local Plan to the Inspectorate in December 2026 and therefore, it will be assessed against the 2024 NPPF.

1.2.3 Notwithstanding the above, our client considers that it is appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.2.4 Paragraph 36 states:
a) "Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant."

1.2.5 Our client does not consider that the emerging Local Plan is 'sound' as it does not accord with criteria b) and c) of Paragraph 36.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation
2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

Table 2.1: Comparison between 2026 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]


2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Annual Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.4 There is clear reduction in the number of 'deliverable' sites on adoption of the Plan, which is a requirement under Paragraph 72 of the NPPF which states:
"Planning Polices should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption."

2.2.5 The weakening of the five year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Melbourn, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption as detailed in Table 2.3 below.

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced table.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that Greater Cambridge's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing Greater Cambridge's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2025 Regulation 18 and 2026 Regulation 19 – Monitoring
[Please refer to the submission attachments for the referenced table.]

2.2.9 The table above demonstrates that there is disparity between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional small and medium-sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable sites upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption
2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has

fallen below the standard method requirement during this period (Figure 2 of the Addendum).

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)³.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply forecast is to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 Greater Cambridge's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites
2.4.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations, with 28% of the supply on the edge of Cambridge, 43% at new settlements (paragraph 3.2.93) and with rural areas only accounting for approximately 14%. It adds that the majority of development at new settlements is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.4.2 The Addendum adds that new allocations will be phased from 2033/34 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2033/34 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement
2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the delivery of the Site for development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.

Cambourne North
2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledge that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be completed between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Melbourn.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site at Water Lane, Melbourn, is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years should mean that Greater Cambridge should allocate more smaller sites to ensure that there is a constant delivery, especially in the first five years. The Site off Water Lane, Melbourn is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land west of Water Lane, Melbourn
2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of land west of Water Lane, Melbourn, would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce the reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainability located.

2.6.3 It is clear that Greater Cambridge considers Melbourn to be a sustainable location as it has allocated 145 homes on two sites in the emerging Local Plan. Therefore, the addition of another 100 homes in this sustainable location is considered to support the aims and objectives of the Greater Cambridge Local Plan.

2.6.4 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the previous Housing Trajectory published as part of the Regulation 18 consultation.

2.6.5 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years of adoption.

3 Conclusion

3.1 Summary
3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered "justified" or "effective" when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Land west of Water Lane, Melbourn, represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 100 homes during the first five years following adoption, thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.6 Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 100 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

3.1.7 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.

Footnotes:
1 Housing Delivery Study Addendum 2026-06-30
2 Cambridge Housing Delivery Study Addendum October 2025
3 Housing supply and delivery - GOV.UK

[Please refer to the submission attachments for the appendices.]

Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 100 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

Please refer to the submission attachments for the correctly formatted full submission, which includes figures and tables.

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of Cala Management Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 Our client has an interest at land west of Water Lane, Melbourn, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details on site context and Cala Management Ltd are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity.

1.2 Regulation 19 Consultation
1.2.1 The Regulation 19 Consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge to submit the emerging Local Plan to the Inspectorate in December 2026 and therefore, it will be assessed against the 2024 NPPF.

1.2.3 Notwithstanding the above, our client considers that it is appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.2.4 Paragraph 36 states:
a) "Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant."

1.2.5 Our client does not consider that the emerging Local Plan is 'sound' as it does not accord with criteria b) and c) of Paragraph 36.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation
2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

Table 2.1: Comparison between 2026 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]


2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Annual Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.4 There is clear reduction in the number of 'deliverable' sites on adoption of the Plan, which is a requirement under Paragraph 72 of the NPPF which states:
"Planning Polices should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption."

2.2.5 The weakening of the five year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Melbourn, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption as detailed in Table 2.3 below.

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced table.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that Greater Cambridge's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing Greater Cambridge's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2025 Regulation 18 and 2026 Regulation 19 – Monitoring
[Please refer to the submission attachments for the referenced table.]

2.2.9 The table above demonstrates that there is disparity between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional small and medium-sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable sites upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption
2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has

fallen below the standard method requirement during this period (Figure 2 of the Addendum).

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)³.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply forecast is to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 Greater Cambridge's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites
2.4.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations, with 28% of the supply on the edge of Cambridge, 43% at new settlements (paragraph 3.2.93) and with rural areas only accounting for approximately 14%. It adds that the majority of development at new settlements is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.4.2 The Addendum adds that new allocations will be phased from 2033/34 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2033/34 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement
2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the delivery of the Site for development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.

Cambourne North
2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledge that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be completed between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Melbourn.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site at Water Lane, Melbourn, is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years should mean that Greater Cambridge should allocate more smaller sites to ensure that there is a constant delivery, especially in the first five years. The Site off Water Lane, Melbourn is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land west of Water Lane, Melbourn
2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of land west of Water Lane, Melbourn, would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce the reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainability located.

2.6.3 It is clear that Greater Cambridge considers Melbourn to be a sustainable location as it has allocated 145 homes on two sites in the emerging Local Plan. Therefore, the addition of another 100 homes in this sustainable location is considered to support the aims and objectives of the Greater Cambridge Local Plan.

2.6.4 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the previous Housing Trajectory published as part of the Regulation 18 consultation.

2.6.5 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years of adoption.

3 Conclusion

3.1 Summary
3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered "justified" or "effective" when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Land west of Water Lane, Melbourn, represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 100 homes during the first five years following adoption, thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.6 Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 100 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

3.1.7 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.

Footnotes:
1 Housing Delivery Study Addendum 2026-06-30
2 Cambridge Housing Delivery Study Addendum October 2025
3 Housing supply and delivery - GOV.UK

[Please refer to the submission attachments for the appendices.]

The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of land west of Water Lane, Melbourn, would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 100 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

Please refer to the submission attachments for the correctly formatted full submission, which includes figures and tables.

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of Cala Management Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 Our client has an interest at land west of Water Lane, Melbourn, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details on site context and Cala Management Ltd are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity.

1.2 Regulation 19 Consultation
1.2.1 The Regulation 19 Consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge to submit the emerging Local Plan to the Inspectorate in December 2026 and therefore, it will be assessed against the 2024 NPPF.

1.2.3 Notwithstanding the above, our client considers that it is appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.2.4 Paragraph 36 states:
a) "Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant."

1.2.5 Our client does not consider that the emerging Local Plan is 'sound' as it does not accord with criteria b) and c) of Paragraph 36.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation
2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

Table 2.1: Comparison between 2026 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]


2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Annual Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.4 There is clear reduction in the number of 'deliverable' sites on adoption of the Plan, which is a requirement under Paragraph 72 of the NPPF which states:
"Planning Polices should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption."

2.2.5 The weakening of the five year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Melbourn, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption as detailed in Table 2.3 below.

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced table.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that Greater Cambridge's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing Greater Cambridge's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2025 Regulation 18 and 2026 Regulation 19 – Monitoring
[Please refer to the submission attachments for the referenced table.]

2.2.9 The table above demonstrates that there is disparity between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional small and medium-sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable sites upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption
2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has

fallen below the standard method requirement during this period (Figure 2 of the Addendum).

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)³.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply forecast is to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 Greater Cambridge's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites
2.4.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations, with 28% of the supply on the edge of Cambridge, 43% at new settlements (paragraph 3.2.93) and with rural areas only accounting for approximately 14%. It adds that the majority of development at new settlements is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.4.2 The Addendum adds that new allocations will be phased from 2033/34 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2033/34 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement
2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the delivery of the Site for development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.

Cambourne North
2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledge that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be completed between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Melbourn.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site at Water Lane, Melbourn, is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years should mean that Greater Cambridge should allocate more smaller sites to ensure that there is a constant delivery, especially in the first five years. The Site off Water Lane, Melbourn is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land west of Water Lane, Melbourn
2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of land west of Water Lane, Melbourn, would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce the reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainability located.

2.6.3 It is clear that Greater Cambridge considers Melbourn to be a sustainable location as it has allocated 145 homes on two sites in the emerging Local Plan. Therefore, the addition of another 100 homes in this sustainable location is considered to support the aims and objectives of the Greater Cambridge Local Plan.

2.6.4 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the previous Housing Trajectory published as part of the Regulation 18 consultation.

2.6.5 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years of adoption.

3 Conclusion

3.1 Summary
3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered "justified" or "effective" when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Land west of Water Lane, Melbourn, represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 100 homes during the first five years following adoption, thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.6 Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 100 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

3.1.7 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.

Footnotes:
1 Housing Delivery Study Addendum 2026-06-30
2 Cambridge Housing Delivery Study Addendum October 2025
3 Housing supply and delivery - GOV.UK

[Please refer to the submission attachments for the appendices.]