Greater Cambridge Local Plan: Proposed Submission

Policy S/DS Development Strategy
-Modify Policy S/DS and its supporting text to include a broader range of sites to specifically include a small and medium site allocations to provide a greater degree of flexibility to the housing land supply, certainty for SMEs and more resilience to the Plan.
-Modify Policy S/DS to increase the level of growth proposed to the Rural Areas of South Cambridgeshire to support the vitality of existing communities.
Allocate ‘Land at 56 Histon Road, Cottenham, as a suitable medium size site for residential development for up to 34 dwellings in line with the application submitted to the Council (ref: 24/03961/FUL).
- Amend the Policies Map to identify the proposed allocation and make the necessary amendment to
Cottenham's defined development extent, this should also reflect the consented development immediately to the east of the Site.
- Add the site to the housing trajectory with a realistic contribution during the first five years following adoption, given the site’s suitability, immediate availability and the intentions of Living Space Housing to bring forward residential development on the site as previously set out in previous representations to the GCLP.

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

Policy S/SH Settlement Hierarchy
- Modify Policy S/SH and its supporting text to retain Cottenham as a Rural Centre. The hierarchy methodology should also be updated in the Settlement Hierarchy Study and supporting text so that Cottenham's role is assessed in light of its proximity and accessibility to the existing Guided Busway, as well as its functional relationship with Northstowe and Waterbeach over the Plan period with the
existing and planned infrastructure. The Guided Busway provides a fast public transport corridor for journeys to Cambridge, Huntingdon, St Ives and the rest of Cambridgeshire, which is a significant sustainable benefit accessible, particularly in terms of sites located on the western side of Cottenham.

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

We object to the omission of the parcel that forms objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire, which have been identified in previous submissions by LSH to early iterations of the GCLP as a suitable site for housing (HELAA Site ID: 115441). We object to the failure to allocate the site for housing development.

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

Allocate ‘Land at 56 Histon Road, Cottenham, as a suitable medium size site for residential development for up to 34 dwellings in line with the application submitted to the Council (ref: 24/03961/FUL).

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying
on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more
justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

Allocate ‘Land at 56 Histon Road, Cottenham, as a suitable medium size site for residential development for up to 34 dwellings in line with the application submitted to the Council (ref: 24/03961/FUL).

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying
on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more
justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

Allocate ‘Land at 56 Histon Road, Cottenham, as a suitable medium size site for residential development for up to 34 dwellings in line with the application submitted to the Council (ref: 24/03961/FUL).

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying
on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more
justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

Allocate ‘Land at 56 Histon Road, Cottenham, as a suitable medium size site for residential development for up to 34 dwellings in line with the application submitted to the Council (ref: 24/03961/FUL).

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying
on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more
justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.

Allocate ‘Land at 56 Histon Road, Cottenham, as a suitable medium size site for residential development for up to 34 dwellings in line with the application submitted to the Council (ref: 24/03961/FUL).

HELAA
- Update the HELAA to assess the full extent of the site as submitted previously to the Council, in particular Living Space Housing’s representations in January 2026 to the Regulation 18 consultation and take account of the live application submitted for this site (ref: 24/03961/FUL) rather than relying
on previous characterisation of the site made by the Council of the location of the site being isolated.

Summary
The above changes would address the identified legal-compliance concern and make the Plan more
justified, effective, positively prepared and consistent with national policy.

Living Space Housing (LSH) objects to the omission of Land At 56 Histon Road Cottenham Cambridgeshire (HELAA Site ID: 115441) and seeks its allocation as a suitable site for residential development. In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report (August 2021) for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:

Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space.

The full extent of the Site is shown on the extract below.

The complete representation is provided on the attached Section 3 continuation sheets and forms part of this response.

Section 3 Continuation Sheet
Representation by Living Space Housing concerning Land at 56 Histon Road,
Cottenham - proposed residential allocation
1. Introduction
Living Space Housing objects to the omission of Land at 56 Histon Road, Cottenham (Site ID: 115441; and HELAA (2023) Site ID 40218) from the Proposed Submission Local Plan.

The land should be assessed as a suitable site that can deliver housing development within the plan period to assist the Council in meeting its housing requirement. The site is available and there are no technical constraints to would prevent the site coming forward now to deliver up to 34 dwellings which will support the services and facilities in Cottenham. The live planning application on the site demonstrates that through a landscape led approach, as is proposed, the site can come forward in
the short term.

These representations also object to the proposed downgrading of Cottenham from a Rural Centre
to a Minor Rural Centre and the failure of the Settlement Hierarchy in Draft Policy S/SH of the GCLP
and Sustainability Appraisal to reflect Cottenham's present and future strategic context. Cottenham is a substantial and well-served village which lies between Northstowe to the west and Waterbeach New Town to the east. It is not an isolated rural location which will become increasingly integrated into a wider network of homes, employment, education, retail, community facilities and sustainable
transport during the Plan period when the strategic developments at both Northstowe continue to be delivered and Waterbeach comes forward.

2. Site context and suitability
LSH control land at 56 Histon Road, a greenfield site with some development used as a sawmill. The village of Cottenham is located to the north-west of Histon Road, providing a variety of services and facilities for local residents. The site is within a sustainable location, with the closest bus stop a short walk from the site (approximately 120m to the South along Histon Road) providing connections from Cottenham to Cambridge. Cambridge Nort Station and Cambridge Station are both within 10km
from the site, providing further services to key national locations, such as London, Birmingham and
Stansted Airport.

The site is not subject to onerous planning constraints. It is not located within a Conservation Area, nor is it subject to any TPOs, or Public Rights of Way (PRoWs). In 2021, the site was subject to a Green Belt review within the Greater Cambridge Green Belt Assessment Final Report August 2021 for potential release (ref: CH10). During this review, it was concluded that the site makes limited contributions to the overall Green Belt and could be potentially released with minimal impact. The Council concluded:
Parcel CH10 makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting, and a limited contribution to preventing communities in the environs of Cambridge from merging with one another. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Cottenham, would be low.

A current full planning application has been submitted by LSH (ref: 24/03961/FUL) for demolition of existing dwellinghouse at 56 Histon Road and Timber Mill buildings and erection of 34 affordable dwellings with access from Histon Road, associated infrastructure, works and open space. During the statutory consultation period, it has been acknowledged by the Local Highways Authority
that this site benefits from pedestrianised links via an existing shared footway/cycleway on the opposite (eastern) side of the carriageway.

3. Cottenham's strategic role
The proposed changes to Cottenham’s settlement status through Policy S/SH Settlement Hierarchy are not justified or robust. The Council's evidence records that Cottenham scored 15 points in the Settlement Hierarchy Study and has 28 shops and services, a primary school and GP
surgery, recreation and community facilities and local employment. By comparison, Gamlingay and
Girton each scored 7 but are placed in the same Minor Rural Centre tier.

Cottenham's proposed downgrading is primarily due to the reduction in frequency of the number 8 bus to a 40-minute service and the conclusion that Cottenham has no segregated public transport route.

This approach fails to take account that Cottenham occupies a strategic position between two of
Greater Cambridge's principal growth locations: namely Northstowe to the west and Waterbeach New Town to the east. Both will deliver substantial housing alongside employment, education, retail, leisure, community and transport infrastructure with the Plan period. These developments will materially alter the level of services and facilities available to Cottenham over the Plan period.
The Site has a strong functional relationship westward towards Northstowe, Longstanton and the Guided Busway. The site is approximately 2.5 km as the crow flies from Longstanton Guided Busway/Park and Ride, this is significant in that the Guided Busway/ Park and Ride provides frequent bus services and bus rapid transit which connects Cambridge to Huntingdon, St Ives other parts of
Cambridgeshire. Cyclists can connect to the Guided Busway via direct, safe cycle route adjoining the Guided Busway.

The Sustainability Appraisal itself recognises at paragraph 4.43 that increased delivery rates at Northstowe and Waterbeach could enable the critical mass for new services and facilities to come forward more quickly. It also takes future rail, public transport and service provision into account when assessing Cambourne and new settlements. It is inconsistent therefore not to consider the corresponding effect of committed growth and infrastructure on Cottenham's future role in South
Cambridgeshire.

In this regard it is pertinent to note that both New Towns are existing allocations where development
is coming forward, with Northstowe being a mixed-use allocation of 10,180 homes, including 6,201
in the Plan period, specialist accommodation and 20 hectares of employment land which is the
closest and Waterbeach New Town a mixed-use development of 11,000 homes, including 5,629 in
the Plan period, with employment, retail and transport infrastructure. The above reinforces the need
to assess Cottenham's role over the Plan period as a whole given the wider opportunities that exist
from its close proximity to Northstowe and Waterbeach and the planned improvements to
infrastructure associated with these areas, rather than through a snapshot of present bus frequency.

5. Spatial Housing Strategy, delivery and resilience
The Plan identifies in Policy S/JH a need for 48,069 homes reflecting an annual need for 2,289
homes to meet the local housing needs.
Policy S/DS (Development Strategy) identifies a total housing supply of 52,032 dwellings to be
delivered over the plan period (2024-2045). This is defined as providing a 8.3% headroom against
the minimum housing need.
Appendix D of the GCLP Reg 19 Plan sets out the Housing Trajectory for the plan period, whilst the
site specific schedules underpinning the trajectory are set out separately, in the Development
Strategy Topic Paper Appendix 10: Housing Trajectory for the Local Plan.
Policy S/DS sets out the Development Strategy which relies heavily on a number of new Settlements
some (44% of growth) with 30% of growth proposed on the edge of Cambridge; 11% at Cambridge
Urban Area and only 15% to the Rural Areas.
The Proposed Strategy relies heavily on New Settlements and large strategic sites with which there
is a need for the provision of a significant level of infrastructure. This requires a long lead in time and
has an associated risk in terms of deliverability, particularly in light of current economic conditions.
The allocation of a range of sites, including small and medium sites, would provide a more robust
strategy and certainty of delivery.
The Development Strategy acknowledges that sustained delivery at or above the annual requirement
is not anticipated until the second half of the Plan period due to the scale of the strategic sites and
due to water and transport constraints. The Housing Trajectory relies heavily on large strategic
developments coming forward in line with the Housing Trajectory, any delay in these sites coming
forward which make up a substantial amount of the supply, would therefore have a significant effect
on the overall housing trajectory which reinforces the need to have more flexibility in the supply of
sites, particularly in the early part of the Plan period.
The delivery of the overall housing requirement is heavily reliant on a relatively small number of very
large scale urban extensions and New Settlements, notably Northstowe, Water Beach New Town,
Bourne Airfield New Village, Cambridge East, North West Cambridge, Cambourne North and Grange
Farm New Settlement. These proposals are projected to deliver around 24,000 new homes by 2045.
The delivery of these allocations is critical to the implementation of the development strategy.
Within Appendix D the Council have applied ‘peak’ delivery (build out rates) for these large-scale
sites amounting to 300 dwellings per annum for the New Settlements and 350 dpa on the other urban
extensions adjacent to Cambridge.
The projected ‘peak’ annual delivery on the large scale allocations pre-dates evidence recently
issued by the Home Builders Federation (HBF) in ‘The Viability Crunch’ in May 2026 which estimates
that cumulatively policy costs, taxes and inflation have added around £76,000 per home over the
past five years, significantly more than the average house price inflation in the same year. This has
implications for both the viability and the pace of delivery of new homes, as where costs rise, but
land values do not or cannot adjust sufficiently, Section 106 and affordable housing contributions
may need to be reduced to ensure development can still come forward. Addressing these and other
site specific issues could lead to a slow down or delay sites or phases of sites from coming forward,
which would undermine delivery projections.
The assumed delivery rate on the strategic sited of 250 dpa is derived from past delivery prior to
COVID and prior to the costs of development now facing developers.
It is also pertinent to note that the Housing Delivery Study Addendum 2025 (update) recognises that
‘market absorption’ is a real issue for Greater Cambridgeshire, given the concentration of large scale
allocations adjacent to Cambridge City (see para 5.40 of the report). The update also accepts that
providing development in the villages, (alongside urban extensions and new settlements) will provide a wider choice of housing in the market for people in terms of size of location and will increase the
market absorption rate.
On the basis of the above the use ‘peak’ delivery rate is not considered to be a robust approach for
the plan period supply projections over the medium to long term and is not soundly based. The
trajectory should be revised so it uses the previous assumptions of 250dpa unless clear evidence
demonstrates that higher rates are justified on specific sites.
Proportion of Growth to Rural Areas
As set out previously Living Space Housing consider that a higher level of growth should be directed
to the Rural Areas to maintain their vitality, to support existing services and to ensure a suitable
supply of homes, including affordable housing and specialist housing. This is contrary to the strategy
in the plan which sets out that villages should play only a limited role in meeting future development
needs.
Cottenham is considered to be a sustainable settlement to accommodate further growth given its
population, the services and facilities it offers, its proximity to the Bus Gateway/ Rapid public
transport corridor and its close proximity to both Northstowe and Water beach as set out earlier in
these representations.
The Sustainability Appraisal (July 2026) recognises at paragraph 4.34 that infrastructure delays,
competition between major sites and similar housing products may reduce build-out rates. This
should be addressed as set out in these representations through with the provision of a wide range
of sites within the Strategy, in different locations with the inclusion in particular of small and medium
size sites in line with the NPPF 2026 which can provide a greater degree of resilience rather than a
heavy reliance on few strategic sites will mya not deliver precisely as forecast.
As previously set out in Living Spaces’ representations to the Reg 18 Plan, small and medium size
sites can make an important contribution to meeting the housing requirements of an area, they are
also are essential for Small and Medium Enterprise housebuilders to deliver new homes and are
often built out relatively quickly. There is also a need to allocate a diverse range of sites to support
and enhance the vitality of rural communities and enable services to grow and thrive as set out in
NPPF 2026, Policy H06:Planning for a diverse mix of sites.
The provision of a diverse range and mix of sites, in the rural areas would complement, rather than
compete with, Northstowe and Waterbeach, whilst benefitting from the services and facilities in those
new settlements. The SA accepts at paragraph 4.41 that village growth can support the viability of
existing services and facilities, but that benefit is not properly reflected in the treatment of Cottenham
in the emerging Settlement Hierarchy or this site.
The allocation of small and medium sites such as Land at 56 Histon Road, Cottenham, would
assist the Council in meeting its housing needs in the short and medium term. Land at 56 Histon
Road, Cottenham is within a sustainable location, immediately adjacent to residential development
and its allocation for housing development would support the existing services and facilities in
Cottenham.
7. National policy and tests of soundness
The below summarises the key considerations in terms of conflict with the tests of soundness:
Justified: The omission of Land at 56 Histon Road, Cottenham is not based on a proportionate
assessment of reasonable alternatives. The site lies immediately adjacent to the built up residential
area of Cottenham, and the accessibility assessment does not consistently take account of the
nearby strategic growth at either Northstowe or Waterbeach.

Effective: The Plan's reliance on large strategic sites which have not delivered as previously
anticipated and the delivery assumptions in the Housing Trajectory are overly ambitious, the limited
headroom does not provide sufficient flexibility and contingency in the supply risks. The allocation of
Land at 56 Histon Road, Cottenham which is suitable, available and achievable, would assist in
providing a more resilience housing supply particularly in the short to medium term.
Consistent with national policy: The strategy does not secure a sufficiently responsive supply or
properly recognise the contribution that small and medium-sized sites can make to meeting housing
needs and sustaining rural communities. There is a need to make proper provision and allocate small
and medium size sites in line with the 2026 NPPF to provide flexibility and resilience in the supply,
to support SMEs.
Positively prepared: The Plan should provide a diverse mix of sites and sizes including small and
medium size sites, in difference locations, including in the Rural Areas rather than placing a heavy
reliance on few strategic sites whose delivery depends on major infrastructure, extended lead-in
periods, market conditions and other economic conditions.
8. Conclusion
Land at 56 Histon Road, Cottenham presents an opportunity for a well-designed and deliverable
residential development to be provided in a sustainable settlement whose services, strategic
accessibility and future role have been understated. The Plan should be modified to:
 undertake an assessment of the site as a reasonable alternative within an addendum to the
SA and HRA assessment of the Plan;
 allocate small and medium size sites in the Plan;
 make provision for growth in the Rural Areas and in particular in Cottenham which benefits
from a range of services and facilities and which will benefit in the Plan period from its
proximity to Northstowe and Water Beach
 restore Cottenham to its former Rural Centre tier acknowledging the existing services and
facilities within Cottenham; its location within 2.5km of the Cambridgeshire Guided Busway
providing rapid public transport connections throughout Cambridgeshire; recognising its
strong role in the Rural area which will be strengthened further in the Plan period through the
Plan Strategy with the strategic level of development committed to and coming forward at
both Northstowe and Waterbeach;
 allocate the site as a housing allocation to deliver up to 34 dwellings.