Greater Cambridge Local Plan: Proposed Submission

Changes to the Plan

2.21. The Local Plan should be modified in order to address the matters of soundness raise above. Additional allocations should be made sustainable peri-urban and rural locations that can come forward quickly and support the overall delivery of the plan. This should include further development at Fulbourn.

2.22. Sites such as Land South of Shelford Road, Fulbourn (the Site), which measures approximately 14ha and would deliver approximately 300 dwellings, should be allocated within the Plan to assist with providing a mix of house types and tenures (Appendix 1 - Site Location Plan). Miller Homes is committed to bringing it forward within the next five years thereby providing certainty of housing delivery, reducing reliance on windfall alongside strategic sites, and increasing headroom within the overall housing supply.

2.23. The Site benefits from being within a 12-minute walk to local facilities in Fulbourn village centre including pre-schools, primary school, pharmacy, heath centre, public houses, community centre and library.

2.24. Fulbourn also benefits frequent buses and the Fulbourn greenway which enables multiple forms of active travel (walking, cycling and riding) into Cambridge city centre. Land south of Shelford Road is technically unconstrainted, deliverable and developable and therefore provides Miller Homes an opportunity to maximise existing connectivity and the strong spatial relationship with Cambridge city centre by creating a benchmark project. That will adopt climate change and carbon neutral principles by 2050, directly in line with the Council’s vision.

2.25. The Site can make an immediate contribution to addressing the housing land supply shortfall. As a well-established developer Miller Homes has a long history of delivering sites efficiently. The full range of benefits include:

• Provision of approximately 300 new dwellings, boosting the supply of homes
• Provision of up to 120 affordable homes (40%) in an area where there is significant need, addressing affordability concerns within the Plan area.
• Provision of public open space, with over half the site being green infrastructure with strong active travel connections to Fulbourn recreation ground via Dogget Lane.
• New active travel connections to Cambridge Road linking to Fulbourn Greenway into Cambridge City Centre including Fulbourn hospital and Peterhouse Technology Park to the west as well as links into Cambridge City supporting the Vision for Cambridge.
• Support and enhancement of local community facilities and village vitality, including the including a health centre, primary schools, pre-schools, library, and recreation ground in accordance with NPPF Paragraph 83.
• Provision of new green space for wildlife with Biodiversity Net Gain exceeding 10% across all metrics.
• Sustainable location within walking distance of the local community facilities including a health centre, primary schools, pre-schools, a food store, library, and recreation ground and public house alongside a regular bus service every 15 minutes into Cambridge City Centre.
• Economic benefits arising from jobs created during the construction phase, and the contribution of future residents towards local economic growth.

Policy S/DS: Spatial Development Strategy

2.1. Miller Homes objects to Policy S/DS: Spatial Development Strategy on the grounds that it is not justified in relation to the approach taken to strategic sites (Part 2 of the Policy). NPPF Paragraph 36(b) requires plans to be justified through an appropriate strategy, informed by proportionate evidence and reasonable alternatives. Miller Homes considers the growth strategy is not appropriate due to its over reliance on new settlements and strategic growth locations. This is especially so given the other reasonable alternatives supported by the evidence base. The Plan is therefore not sound and this is considered further in the sections below.

Vision for Greater Cambridge

2.2. Miller Homes supports the underlining Vision for Greater Cambridge which places emphasis on decreasing impact on the climate and environment, through reducing reliance on the private car to create thriving neighbourhoods with a variety of jobs and homes and supporting infrastructure that is needed.

2.3. However, it is considered that the GCLP fails to fulfil the Vision. This is due to the over reliance on strategic scale sites, totalling 12,550 dwellings (91%) whilst smaller sites total 1,104 (9%) of the 13,654 new allocations. Through delivering housing across large strategic sites, there is an inherent lack of choice of housing choice across the greater Cambridge area. This is particularly relevant to rural areas such as Fulbourn, where maintenance of local vitality and economy is missed in favour of new settlements and large-scale strategic development contrary to paragraph 83 of the NPPF.

2.4. Furthermore, NPPF paragraphs 11a and 110 state that all plans should promote a sustainable pattern of development, in locations which are or can be made sustainable. It is considered that the allocation of new housing on strategic sites that are outside Cambridge Centre and beyond the Green Belt, is not sustainable. This is due to the potential over reliance on the private vehicle to be able to access services, facilities and employment opportunities. The Sustainability Appraisal 2026 identifies this as a potential for concern of development ‘jumping’ the Green Belt, meaning some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which will result in disproportionate increases in vehicle travel. Therefore, the Development Strategy as proposed is not considered to meet the Plan’s Vision and the NPPF’s central premise of a sustainable pattern of development. The Plan is therefore unsound as it is not in accordance with national policy.

Reliance on New Settlements and Strategic Sites

2.5. NPPF Paragraph 36(c) requires plans to be effective and therefore deliverable over the plan period. Miller Homes considers the development strategy fails this test due to its reliance on new settlements and strategic sites, equating to an overdependence on long-term delivery and long lead in times. Whilst it is recognised that the Council has included these schemes to induce sustained growth beyond the initial 5-year housing supply period in accordance with paragraph 72(b) of the NPPF, it is a missed opportunity not to allocate smaller sites to increase headroom and produce a concrete supply regardless of the long lead times within the immediate 5-year period. Therefore, this approach fails to address the need for sustained growth across the plan period.

2.6. Within the new housing allocations, 12,550 are provided on five strategic sites varying in size from 1,000 to 3,950 dwellings. The evidence report Greater Cambridge Housing Development Strategy Topic paper Appendix 10: Housing trajectory (2026), outlines the lead-in times of strategic sites (200 dwellings and above) to be 6 years from allocation to first completions. Miller Homes considers these lead times to be overly ambitious and generalised and suggest that more clarity is needed regarding the site-specific factors regarding lead times and build out rates. This approach should take account of the current lead times facing developers, irrespective of past performance, alongside current viability constraints facing developers nationwide. Furthermore, there are often delays on strategic sites of this scale due site-specific constraints or external factors like the Government’s announcement that it will not be funding the Cambridge Waste Water Treatment Plant which has impacted the delivery of the North East Cambridge site.

2.7. Despite the Councils retaining confidence in this approach in the Housing Delivery Study (Addendum 2026 Update), more clarity is needed regarding the site-specific factors regarding build out rates and lead in times.

2.8. For instance, Cambridge East (Airport) is due to see first completions in 2032/33, on the Councils’ average 6-year lead in time, this would mean a planning application is submitted within the next year. On this assumption, determination and a Section 106 agreement would have to be completed within 2 to 3 years, with infrastructure, land assembly, conditions discharge, pre-commencement works and reserved matters approvals all completed for a start on site in no later than 2031/32. This is considered ambitious for the scale of the site, noting the existing occupiers and given the current market.

2.9. Similarly, the delivery rate is very high at 350dpa from 2035/36 to 2044/45. Whilst the Councils’ state that the 350dpa is a ‘peak’, this is contested given it is sustained for such a long period of time. The average over 13 years of delivery is still over 300dpa. It would be more appropriate to assume an average delivery rate based on evidence of past performance in Cambridgeshire.. For instance, Lichfield’s Start to Finish Report 2024 details the considerable range in delivery rates in Cambridgeshire. Table 1 sets out the mean build out rate (DPA) for 8 established strategic sites, each with more than four years of build out data. These sites have progressed through a range of economic climates, including periods of abundancy alongside times of crisis and flux (e.g. the 2008 financial crisis and the 2020 coronavirus pandemic).

Site Mean DPA
Great Kneighton (Clay Farm) 218.8
Cambourne (original new settlement) 188.0
Northstowe Phase 1 184.7
North West Cambridge 148.7
Upper Cambourne 105.6
Trumpington Meadows 96.4
Orchard Park 79.2
North Ely (Orchards Green) 62.3
Table 1: Mean build out rates across eight established strategic sites in Cambridgeshire

2.10. To this end, this data provides a robust and justified evidence base for assessing realistic delivery performance. The data indicates that large strategic sites (urban extensions and new settlements) have been built out at an average rate of 135.5 dpa and no site exceeds a 220 dpa average well below the forecasted 300dpa for new settlements or 350dpa for urban extensions. Therefore, Miller consider the forecasted rates need to be recalculated using the average dpa across these entirety of these sites rather than the peak when calculating housing delivery, to avoid overestimating future completions, factor in economic flux and ensure that assumptions are deliverable and justified against previous performance.




2.11. Therefore, Miller Homes does not support the paragraph 2 of Policy S/DS: Development Strategy in regard to overreliance on strategic sites. It is considered that this approach, fails to produce sufficient sites that can come forward both within the next 5 years and over the plan period. The plan is therefore, considered ineffective as it does not accord with paragraph 36(C) of the NPPF.

2.12. It is with this understanding that Miller Homes consider that additional sites should be allocated for the Plan to accord with the provision of deliverable and available sites as stipulated by NPPF Paragraph 72 and support a robust 5 year housing land supply position and guard against any potential delays that may arise with the strategic sites over the plan period.

Windfall allowance and the need for medium scale deliverable schemes

2.13. Paragraph 75 of the NPPF states that “where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply”. The Greater Cambridge Housing Delivery Study Addendum Update (2026) utilises historic data from 2006-2024 to base future trends. This has identified a delivery of 425 windfall dwellings per annum. In the review of expected future trends, national policy changes in relation to developing brownfield sites has been identified to highlight how it will be easier to bring brownfield sites forward. However, the assumption that windfall sites will be delivered on mainly brownfield sites is questioned. This is due to there being fewer opportunities as many sites have already been utilised, with a potential decrease in brownfield churn. Furthermore, in the Main Viability Report produced by Aspinall Verdi (2026) small brownfield sites have been identified as being susceptible to fluctuations and the potential of low viability meaning the Councils may have to take a more flexible approach to contributions

2.14. Furthermore, the Plan currently starts making an allowance for windfalls from 2029/30. However, the Plan is anticipated to be adopted in 2028. Whilst the current base takes account of commitments up to March 2026, and thus there is a 3-year gap between windfalls and commitments, the Councils will need to ensure that this is rolled forward as the Plan progresses. There is otherwise a danger of double counting completions from existing commitments and windfalls. This could reduce the supply in the first 5 years and the plan period by as much as 850 homes. For a plan adoption of 2028, windfalls should not be considered as a source of supply until 2031/32.

2.15. For these reasons, therefore, the assessment of the windfall allowance is not sufficiently compelling that it will continue to be a reliable source of supply.

Rural centres and Minor Rural Centres
2.16. Miller Homes does not support the part 3(b) of Policy S/DS: Development Strategy due to the failure to include active and/ or sustainable transport as a factor when determining service provision. This addition would support the vision for Cambridge reducing vehicle reliance and promoting sustainable patterns of development in line with NPPF paragraph 73.

2.17. Miller Homes consider that the policy should be reworded to include active travel links such as greenways, cycle paths and public rights of way to support connectivity to Cambridge and the trains stations rather than solely referring to public transport.


Housing and Landscape Evidence

2.18. It is noted that the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA – October 2025) assessed the Land South of Shelford Road, Fulbourn (Reference: 40501 / 115137). The HELAA raised concerns about the development of the site impacting the landscape character of the area and on key views to and from the village of Fulbourn, this view is disputed. A review of the Landscape Sensitivity Assessment has been undertaken and is included in appended ‘Representations (Landscape and Visual Issues)’ (Appendix 2). This assessment includes a set of views of Land South of Shelford Road, Fulbourn from the local highways and PRoWs, as well as a Screened Zone of Theoretical Visibility plan. These assessments conclude that the overwhelming majority of the nearby visual receptors and those in the wider countryside would not be affected or effects would be limited were the site at Land South of Shelford Road, Fulbourn to be allocated. The landscape sensitivity assessment supports the site as an appropriate site for development.

2.19. The site is also assessed within the Greater Cambridge Landscape Sensitivity Assessment (November 2021) as part of a larger Assessment Unit FUL05 of medium sensitivity to residential and mix-use developments. This assessment identifies that with medium landscape sensitivity any landscape character effects of the development of Land South of Shelford Road, Fulbourn Site would be moderated and therefore appropriate for allocation as an Edge of Cambridge site.

2.20. Therefore, it is considered that Land South of Shelford Road, Fulbourn is an appropriate Edge of Cambridge allocation that would provide a variety and choice of housing in a sustainable location.

Policy S/SH: Settlement Hierarchy
The role of the settlement hierarchy

2.26. The Settlement Hierarchy groups settlements into categories that reflect their scale, characteristics and sustainability to ensure development is located in the most sustainable places.

2.27. Fulbourn is currently identified as a Minor Rural Centre, which limits residential development to schemes of up to 30 dwellings. Whilst this approach seeks to protect local character, in the case of Fulbourn it is contrary to the village's indicative neighbourhood plan housing requirement of 101 new homes. Fulbourn is a highly sustainable location, benefiting from strong sustainable transport links to Cambridge, including the improved cycleway, and a range of services and facilities within the village centre, including a health centre, primary schools, pre-schools, a food store, library, and recreation ground. These characteristics are comparable to those of settlements identified as Rural Centres, such as Great Shelford and Stapleford, Histon and Impington, and Sawston. As such, Fulbourn exhibits the attributes of a Rural Centre, and its settlement classification should therefore be amended.

2.28. Furthermore, Fulbourn has good access to a secondary school with links to The Netherall School; employment opportunities with Fulbourn hospital and Peterhouse Technology Park to the west as well as links into Cambridge City. Reclassifying Fulbourn as a Rural Centre would better reflect its sustainability credentials aligning with the vision for Cambridge, reflecting its status with comparable settlements and supporting rural vitality in accordance with paragraphs 72 and 83 of the NPPF.

2.29. The infrastructure of Fulbourn can accommodate new homes. The local primary school is at 80% capacity in the 25/26 academic year and is predicted to rise to 92% in 29/30 academic year as demonstrated in the 2025 primary pupil forecasts , making the settlement a sustainable choice from an education standpoint. In accordance with NPPF Paragraph 83, development that supports local services and enhances the vitality of rural communities should be identified in planning policies.

Policy S/GB: The Cambridge Greenbelt
2.30. Policy S/GB and supporting evidence in the Green Belt Assessment (2026), concludes that there is no requirement to release the Green Belt as it is considered that ‘exceptional circumstances’ are not in place.

2.31. Paragraph 148 of the NPPF states that when reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location is appropriate. However, the new site allocations, do not present sustainable patterns of development, due to the proposal to deliver new strategic sites beyond the Green Belt. This means that these sites will not be located near Cambridge Centre and have the potential to manufacture over reliance on the private car to access services, facilities and employment, therefore not being in compliance with paragraph 110 and 115 of the NPPF. This stance is supported by conclusions in the Sustainability Appraisal 2025, which identifies the potential impacts of development ‘jumping’ the Green Belt, as some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which may result in increases in vehicle travel.
Grey Belt assessment

2.32. The Greater Cambridge Greenbelt assessment review (2026) does not accord with national policy guidance. The methodology has gone beyond a reasonable interpretation of Purpose D, which is to preserve the setting and special character of historic towns. National planning guidance is clear that this refers to towns, not villages. Furthermore, in order to make a strong contribution it should be a considerable contribution. Whilst the list in the PPG is not exhaustive it suggests that this could be a result of being adjacent to, within or of significant visual importance to the historic aspects of the town.

2.33. It is therefore a significant over-extrapolation for the methodology to result in virtually all parcels in villages close to Cambridge making a strong contribution to purpose D, especially given it should be relative to the historic aspects of the town and should have visual importance.

2.34. For instance, parcel FU16, purportedly makes a strong contribution to purpose D and would result in high levels of harm. However, Miller Homes considers under the definition of Grey Belt land and relevant national planning guidance, the site does not make a strong contribution to Green Belt purposes (a), (b) or (d). This is laid out below:
Purpose A – to check the unrestricted sprawl of large built-up areas
2.35. There are physical features in reasonable proximity that could contain development namely hedgerows, Shelford Road to the north-west and Babraham Road to the east and rather its development would help foster a natural settlement boundary to the village of Fulbourn.

Purpose B – to prevent neighbouring towns merging into one another

2.36. The Site does not form a substantial part of a gap between towns, and there would be no loss of visual separation of towns. This is supported by the initial Green Belt Assessment in 2021 which stated that the parcel made a limited/ no contribution to this aim.

Purpose D – to preserve the setting and special character of historic towns

2.37. The Site does not form part of the setting of a historic town as Fulbourn is a village. Furthermore, the Miller’s land interests within FU16 show a Zone of Theoretical Visibility (see Appendix 2) that does not extend into the historic aspects of Cambridge.

3. Conclusion
3.1. Miller Homes considers that the Greater Cambridge Local Plan, in its current form, fails to meet the NPPF tests of soundness at Paragraph 36. Specifically:
• The Plan is not justified (NPPF Paragraph 36(b)) – the growth strategy relies on new settlements and strategic growth locations without adequate consideration of reasonable alternatives, including meeting the housing need in areas such as Fulbourn.
• The Plan is not effective (NPPF Paragraph 36(c)) – the reliance on new settlements and strategic sites with long lead-in times, supported by an assumption that lead times and build out will follow existing trends, creates an ineffective strategy that places the Councils’ immediate five-year housing land supply at risk. The Plan also fails to provide for deliverability over the plan period.
• The Plan fails to accord with NPPF Paragraphs 72– by not providing for a mix of sites, including non-strategic sites that are essential for sustained growth and can come forward within the first five years of the plan period.
• The Plan fails to accord with NPPF Paragraph 83 – by neglecting the needs of rural communities and failing to allocate sites that will support and enhance the vitality of rural communities such as Fulbourn.

3.2. Accordingly, Miller Homes consider that, to address these soundness concerns, Land South of Shelford Road, Fulbourn be allocated within the Greater Cambridge Local Plan.

3.3. The site aligns closely with the Councils' Vision for Cambridge, occupies a sustainable location, close to Cambridge city and is capable of early delivery, and would maintain the vitality of Fulbourn. The Site would provide housing in a sustainable and suitable location supported by active travel, housing delivery and long-term place-making objectives.

3.4. Its allocation would increase flexibility within the housing strategy, strengthen the Plan's deliverability and make a meaningful contribution towards maintaining a robust five-year housing land supply upon adoption of the Local Plan.

3.5. NPPF paragraphs 82 and 83 state that planning policies should be responsive to local circumstances and support opportunities to bring forward rural sites to meet local need. Fulbourn is currently classified as a Minor Rural Centre and should it be upgraded to a Rural Centre given the range of services and facilities within the village and within close proximity in the city.

Changes to the Plan

2.21. The Local Plan should be modified in order to address the matters of soundness raise above. Additional allocations should be made sustainable peri-urban and rural locations that can come forward quickly and support the overall delivery of the plan. This should include further development at Fulbourn.

2.22. Sites such as Land South of Shelford Road, Fulbourn (the Site), which measures approximately 14ha and would deliver approximately 300 dwellings, should be allocated within the Plan to assist with providing a mix of house types and tenures (Appendix 1 - Site Location Plan). Miller Homes is committed to bringing it forward within the next five years thereby providing certainty of housing delivery, reducing reliance on windfall alongside strategic sites, and increasing headroom within the overall housing supply.

2.23. The Site benefits from being within a 12-minute walk to local facilities in Fulbourn village centre including pre-schools, primary school, pharmacy, heath centre, public houses, community centre and library.

2.24. Fulbourn also benefits frequent buses and the Fulbourn greenway which enables multiple forms of active travel (walking, cycling and riding) into Cambridge city centre. Land south of Shelford Road is technically unconstrainted, deliverable and developable and therefore provides Miller Homes an opportunity to maximise existing connectivity and the strong spatial relationship with Cambridge city centre by creating a benchmark project. That will adopt climate change and carbon neutral principles by 2050, directly in line with the Council’s vision.

2.25. The Site can make an immediate contribution to addressing the housing land supply shortfall. As a well-established developer Miller Homes has a long history of delivering sites efficiently. The full range of benefits include:

• Provision of approximately 300 new dwellings, boosting the supply of homes
• Provision of up to 120 affordable homes (40%) in an area where there is significant need, addressing affordability concerns within the Plan area.
• Provision of public open space, with over half the site being green infrastructure with strong active travel connections to Fulbourn recreation ground via Dogget Lane.
• New active travel connections to Cambridge Road linking to Fulbourn Greenway into Cambridge City Centre including Fulbourn hospital and Peterhouse Technology Park to the west as well as links into Cambridge City supporting the Vision for Cambridge.
• Support and enhancement of local community facilities and village vitality, including the including a health centre, primary schools, pre-schools, library, and recreation ground in accordance with NPPF Paragraph 83.
• Provision of new green space for wildlife with Biodiversity Net Gain exceeding 10% across all metrics.
• Sustainable location within walking distance of the local community facilities including a health centre, primary schools, pre-schools, a food store, library, and recreation ground and public house alongside a regular bus service every 15 minutes into Cambridge City Centre.
• Economic benefits arising from jobs created during the construction phase, and the contribution of future residents towards local economic growth.

Policy S/DS: Spatial Development Strategy

2.1. Miller Homes objects to Policy S/DS: Spatial Development Strategy on the grounds that it is not justified in relation to the approach taken to strategic sites (Part 2 of the Policy). NPPF Paragraph 36(b) requires plans to be justified through an appropriate strategy, informed by proportionate evidence and reasonable alternatives. Miller Homes considers the growth strategy is not appropriate due to its over reliance on new settlements and strategic growth locations. This is especially so given the other reasonable alternatives supported by the evidence base. The Plan is therefore not sound and this is considered further in the sections below.

Vision for Greater Cambridge

2.2. Miller Homes supports the underlining Vision for Greater Cambridge which places emphasis on decreasing impact on the climate and environment, through reducing reliance on the private car to create thriving neighbourhoods with a variety of jobs and homes and supporting infrastructure that is needed.

2.3. However, it is considered that the GCLP fails to fulfil the Vision. This is due to the over reliance on strategic scale sites, totalling 12,550 dwellings (91%) whilst smaller sites total 1,104 (9%) of the 13,654 new allocations. Through delivering housing across large strategic sites, there is an inherent lack of choice of housing choice across the greater Cambridge area. This is particularly relevant to rural areas such as Fulbourn, where maintenance of local vitality and economy is missed in favour of new settlements and large-scale strategic development contrary to paragraph 83 of the NPPF.

2.4. Furthermore, NPPF paragraphs 11a and 110 state that all plans should promote a sustainable pattern of development, in locations which are or can be made sustainable. It is considered that the allocation of new housing on strategic sites that are outside Cambridge Centre and beyond the Green Belt, is not sustainable. This is due to the potential over reliance on the private vehicle to be able to access services, facilities and employment opportunities. The Sustainability Appraisal 2026 identifies this as a potential for concern of development ‘jumping’ the Green Belt, meaning some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which will result in disproportionate increases in vehicle travel. Therefore, the Development Strategy as proposed is not considered to meet the Plan’s Vision and the NPPF’s central premise of a sustainable pattern of development. The Plan is therefore unsound as it is not in accordance with national policy.

Reliance on New Settlements and Strategic Sites

2.5. NPPF Paragraph 36(c) requires plans to be effective and therefore deliverable over the plan period. Miller Homes considers the development strategy fails this test due to its reliance on new settlements and strategic sites, equating to an overdependence on long-term delivery and long lead in times. Whilst it is recognised that the Council has included these schemes to induce sustained growth beyond the initial 5-year housing supply period in accordance with paragraph 72(b) of the NPPF, it is a missed opportunity not to allocate smaller sites to increase headroom and produce a concrete supply regardless of the long lead times within the immediate 5-year period. Therefore, this approach fails to address the need for sustained growth across the plan period.

2.6. Within the new housing allocations, 12,550 are provided on five strategic sites varying in size from 1,000 to 3,950 dwellings. The evidence report Greater Cambridge Housing Development Strategy Topic paper Appendix 10: Housing trajectory (2026), outlines the lead-in times of strategic sites (200 dwellings and above) to be 6 years from allocation to first completions. Miller Homes considers these lead times to be overly ambitious and generalised and suggest that more clarity is needed regarding the site-specific factors regarding lead times and build out rates. This approach should take account of the current lead times facing developers, irrespective of past performance, alongside current viability constraints facing developers nationwide. Furthermore, there are often delays on strategic sites of this scale due site-specific constraints or external factors like the Government’s announcement that it will not be funding the Cambridge Waste Water Treatment Plant which has impacted the delivery of the North East Cambridge site.

2.7. Despite the Councils retaining confidence in this approach in the Housing Delivery Study (Addendum 2026 Update), more clarity is needed regarding the site-specific factors regarding build out rates and lead in times.

2.8. For instance, Cambridge East (Airport) is due to see first completions in 2032/33, on the Councils’ average 6-year lead in time, this would mean a planning application is submitted within the next year. On this assumption, determination and a Section 106 agreement would have to be completed within 2 to 3 years, with infrastructure, land assembly, conditions discharge, pre-commencement works and reserved matters approvals all completed for a start on site in no later than 2031/32. This is considered ambitious for the scale of the site, noting the existing occupiers and given the current market.

2.9. Similarly, the delivery rate is very high at 350dpa from 2035/36 to 2044/45. Whilst the Councils’ state that the 350dpa is a ‘peak’, this is contested given it is sustained for such a long period of time. The average over 13 years of delivery is still over 300dpa. It would be more appropriate to assume an average delivery rate based on evidence of past performance in Cambridgeshire.. For instance, Lichfield’s Start to Finish Report 2024 details the considerable range in delivery rates in Cambridgeshire. Table 1 sets out the mean build out rate (DPA) for 8 established strategic sites, each with more than four years of build out data. These sites have progressed through a range of economic climates, including periods of abundancy alongside times of crisis and flux (e.g. the 2008 financial crisis and the 2020 coronavirus pandemic).

Site Mean DPA
Great Kneighton (Clay Farm) 218.8
Cambourne (original new settlement) 188.0
Northstowe Phase 1 184.7
North West Cambridge 148.7
Upper Cambourne 105.6
Trumpington Meadows 96.4
Orchard Park 79.2
North Ely (Orchards Green) 62.3
Table 1: Mean build out rates across eight established strategic sites in Cambridgeshire

2.10. To this end, this data provides a robust and justified evidence base for assessing realistic delivery performance. The data indicates that large strategic sites (urban extensions and new settlements) have been built out at an average rate of 135.5 dpa and no site exceeds a 220 dpa average well below the forecasted 300dpa for new settlements or 350dpa for urban extensions. Therefore, Miller consider the forecasted rates need to be recalculated using the average dpa across these entirety of these sites rather than the peak when calculating housing delivery, to avoid overestimating future completions, factor in economic flux and ensure that assumptions are deliverable and justified against previous performance.




2.11. Therefore, Miller Homes does not support the paragraph 2 of Policy S/DS: Development Strategy in regard to overreliance on strategic sites. It is considered that this approach, fails to produce sufficient sites that can come forward both within the next 5 years and over the plan period. The plan is therefore, considered ineffective as it does not accord with paragraph 36(C) of the NPPF.

2.12. It is with this understanding that Miller Homes consider that additional sites should be allocated for the Plan to accord with the provision of deliverable and available sites as stipulated by NPPF Paragraph 72 and support a robust 5 year housing land supply position and guard against any potential delays that may arise with the strategic sites over the plan period.

Windfall allowance and the need for medium scale deliverable schemes

2.13. Paragraph 75 of the NPPF states that “where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply”. The Greater Cambridge Housing Delivery Study Addendum Update (2026) utilises historic data from 2006-2024 to base future trends. This has identified a delivery of 425 windfall dwellings per annum. In the review of expected future trends, national policy changes in relation to developing brownfield sites has been identified to highlight how it will be easier to bring brownfield sites forward. However, the assumption that windfall sites will be delivered on mainly brownfield sites is questioned. This is due to there being fewer opportunities as many sites have already been utilised, with a potential decrease in brownfield churn. Furthermore, in the Main Viability Report produced by Aspinall Verdi (2026) small brownfield sites have been identified as being susceptible to fluctuations and the potential of low viability meaning the Councils may have to take a more flexible approach to contributions

2.14. Furthermore, the Plan currently starts making an allowance for windfalls from 2029/30. However, the Plan is anticipated to be adopted in 2028. Whilst the current base takes account of commitments up to March 2026, and thus there is a 3-year gap between windfalls and commitments, the Councils will need to ensure that this is rolled forward as the Plan progresses. There is otherwise a danger of double counting completions from existing commitments and windfalls. This could reduce the supply in the first 5 years and the plan period by as much as 850 homes. For a plan adoption of 2028, windfalls should not be considered as a source of supply until 2031/32.

2.15. For these reasons, therefore, the assessment of the windfall allowance is not sufficiently compelling that it will continue to be a reliable source of supply.

Rural centres and Minor Rural Centres
2.16. Miller Homes does not support the part 3(b) of Policy S/DS: Development Strategy due to the failure to include active and/ or sustainable transport as a factor when determining service provision. This addition would support the vision for Cambridge reducing vehicle reliance and promoting sustainable patterns of development in line with NPPF paragraph 73.

2.17. Miller Homes consider that the policy should be reworded to include active travel links such as greenways, cycle paths and public rights of way to support connectivity to Cambridge and the trains stations rather than solely referring to public transport.


Housing and Landscape Evidence

2.18. It is noted that the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA – October 2025) assessed the Land South of Shelford Road, Fulbourn (Reference: 40501 / 115137). The HELAA raised concerns about the development of the site impacting the landscape character of the area and on key views to and from the village of Fulbourn, this view is disputed. A review of the Landscape Sensitivity Assessment has been undertaken and is included in appended ‘Representations (Landscape and Visual Issues)’ (Appendix 2). This assessment includes a set of views of Land South of Shelford Road, Fulbourn from the local highways and PRoWs, as well as a Screened Zone of Theoretical Visibility plan. These assessments conclude that the overwhelming majority of the nearby visual receptors and those in the wider countryside would not be affected or effects would be limited were the site at Land South of Shelford Road, Fulbourn to be allocated. The landscape sensitivity assessment supports the site as an appropriate site for development.

2.19. The site is also assessed within the Greater Cambridge Landscape Sensitivity Assessment (November 2021) as part of a larger Assessment Unit FUL05 of medium sensitivity to residential and mix-use developments. This assessment identifies that with medium landscape sensitivity any landscape character effects of the development of Land South of Shelford Road, Fulbourn Site would be moderated and therefore appropriate for allocation as an Edge of Cambridge site.

2.20. Therefore, it is considered that Land South of Shelford Road, Fulbourn is an appropriate Edge of Cambridge allocation that would provide a variety and choice of housing in a sustainable location.

Conclusion

Miller Homes considers that the Greater Cambridge Local Plan, in its current form, fails to meet the NPPF tests of soundness at Paragraph 36. Specifically:
• The Plan is not justified (NPPF Paragraph 36(b)) – the growth strategy relies on new settlements and strategic growth locations without adequate consideration of reasonable alternatives, including meeting the housing need in areas such as Fulbourn.
• The Plan is not effective (NPPF Paragraph 36(c)) – the reliance on new settlements and strategic sites with long lead-in times, supported by an assumption that lead times and build out will follow existing trends, creates an ineffective strategy that places the Councils’ immediate five-year housing land supply at risk. The Plan also fails to provide for deliverability over the plan period.

Accordingly, Miller Homes consider that, to address these soundness concerns, Land South of Shelford Road, Fulbourn be allocated within the Greater Cambridge Local Plan.

The site aligns closely with the Councils' Vision for Cambridge, occupies a sustainable location, close to Cambridge city and is capable of early delivery, and would maintain the vitality of Fulbourn. The Site would provide housing in a sustainable and suitable location supported by active travel, housing delivery and long-term place-making objectives.

Its allocation would increase flexibility within the housing strategy, strengthen the Plan's deliverability and make a meaningful contribution towards maintaining a robust five-year housing land supply upon adoption of the Local Plan.

Fulbourn should be upgraded to a Rural Centre given the range of services and facilities within the village and close proximity in the city.

Policy S/SH: Settlement Hierarchy

The role of the settlement hierarchy

2.26. The Settlement Hierarchy groups settlements into categories that reflect their scale, characteristics and sustainability to ensure development is located in the most sustainable places.

2.27. Fulbourn is currently identified as a Minor Rural Centre, which limits residential development to schemes of up to 30 dwellings. Whilst this approach seeks to protect local character, in the case of Fulbourn it is contrary to the village's indicative neighbourhood plan housing requirement of 101 new homes. Fulbourn is a highly sustainable location, benefiting from strong sustainable transport links to Cambridge, including the improved cycleway, and a range of services and facilities within the village centre, including a health centre, primary schools, pre-schools, a food store, library, and recreation ground. These characteristics are comparable to those of settlements identified as Rural Centres, such as Great Shelford and Stapleford, Histon and Impington, and Sawston. As such, Fulbourn exhibits the attributes of a Rural Centre, and its settlement classification should therefore be amended.

2.28. Furthermore, Fulbourn has good access to a secondary school with links to The Netherall School; employment opportunities with Fulbourn hospital and Peterhouse Technology Park to the west as well as links into Cambridge City. Reclassifying Fulbourn as a Rural Centre would better reflect its sustainability credentials aligning with the vision for Cambridge, reflecting its status with comparable settlements and supporting rural vitality in accordance with paragraphs 72 and 83 of the NPPF.

2.29. The infrastructure of Fulbourn can accommodate new homes. The local primary school is at 80% capacity in the 25/26 academic year and is predicted to rise to 92% in 29/30 academic year as demonstrated in the 2025 primary pupil forecasts , making the settlement a sustainable choice from an education standpoint. In accordance with NPPF Paragraph 83, development that supports local services and enhances the vitality of rural communities should be identified in planning policies.

Miller Homes considers that the Greater Cambridge Greenbelt assessment review (2026) which underpins this policy must be reviewed to accord with National Planning Policy Guidance to avoid strategic sites 'jumping' the greenbelt creating development overly reliant on vehicular travel modes. In particular the methodology has gone beyond a reasonable interpretation of Purpose D, which is to preserve the setting and special character of historic towns. National planning guidance is clear that this refers to towns, not villages.

Policy S/GB: The Cambridge Greenbelt
2.30. Policy S/GB and supporting evidence in the Green Belt Assessment (2026), concludes that there is no requirement to release the Green Belt as it is considered that ‘exceptional circumstances’ are not in place.

2.31. Paragraph 148 of the NPPF states that when reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location is appropriate. However, the new site allocations, do not present sustainable patterns of development, due to the proposal to deliver new strategic sites beyond the Green Belt. This means that these sites will not be located near Cambridge Centre and have the potential to manufacture over reliance on the private car to access services, facilities and employment, therefore not being in compliance with paragraph 110 and 115 of the NPPF. This stance is supported by conclusions in the Sustainability Appraisal 2025, which identifies the potential impacts of development ‘jumping’ the Green Belt, as some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which may result in increases in vehicle travel.
Grey Belt assessment

2.32. The Greater Cambridge Greenbelt assessment review (2026) does not accord with national policy guidance. The methodology has gone beyond a reasonable interpretation of Purpose D, which is to preserve the setting and special character of historic towns. National planning guidance is clear that this refers to towns, not villages. Furthermore, in order to make a strong contribution it should be a considerable contribution. Whilst the list in the PPG is not exhaustive it suggests that this could be a result of being adjacent to, within or of significant visual importance to the historic aspects of the town.

2.33. It is therefore a significant over-extrapolation for the methodology to result in virtually all parcels in villages close to Cambridge making a strong contribution to purpose D, especially given it should be relative to the historic aspects of the town and should have visual importance.

2.34. For instance, parcel FU16, purportedly makes a strong contribution to purpose D and would result in high levels of harm. However, Miller Homes considers under the definition of Grey Belt land and relevant national planning guidance, the site does not make a strong contribution to Green Belt purposes (a), (b) or (d). This is laid out below:
Purpose A – to check the unrestricted sprawl of large built-up areas
2.35. There are physical features in reasonable proximity that could contain development namely hedgerows, Shelford Road to the north-west and Babraham Road to the east and rather its development would help foster a natural settlement boundary to the village of Fulbourn.

Purpose B – to prevent neighbouring towns merging into one another

2.36. The Site does not form a substantial part of a gap between towns, and there would be no loss of visual separation of towns. This is supported by the initial Green Belt Assessment in 2021 which stated that the parcel made a limited/ no contribution to this aim.

Purpose D – to preserve the setting and special character of historic towns

2.37. The Site does not form part of the setting of a historic town as Fulbourn is a village. Furthermore, the Miller’s land interests within FU16 show a Zone of Theoretical Visibility (see Appendix 2) that does not extend into the historic aspects of Cambridge.

Policy S/DS: Spatial Development Strategy

2.1. Miller Homes objects to Policy S/DS: Spatial Development Strategy on the grounds that it is not justified in relation to the approach taken to strategic sites (Part 2 of the Policy). NPPF Paragraph 36(b) requires plans to be justified through an appropriate strategy, informed by proportionate evidence and reasonable alternatives. Miller Homes considers the growth strategy is not appropriate due to its over reliance on new settlements and strategic growth locations. This is especially so given the other reasonable alternatives supported by the evidence base. The Plan is therefore not sound and this is considered further in the sections below.

Vision for Greater Cambridge

2.2. Miller Homes supports the underlining Vision for Greater Cambridge which places emphasis on decreasing impact on the climate and environment, through reducing reliance on the private car to create thriving neighbourhoods with a variety of jobs and homes and supporting infrastructure that is needed.

2.3. However, it is considered that the GCLP fails to fulfil the Vision. This is due to the over reliance on strategic scale sites, totalling 12,550 dwellings (91%) whilst smaller sites total 1,104 (9%) of the 13,654 new allocations. Through delivering housing across large strategic sites, there is an inherent lack of choice of housing choice across the greater Cambridge area. This is particularly relevant to rural areas such as Fulbourn, where maintenance of local vitality and economy is missed in favour of new settlements and large-scale strategic development contrary to paragraph 83 of the NPPF.

2.4. Furthermore, NPPF paragraphs 11a and 110 state that all plans should promote a sustainable pattern of development, in locations which are or can be made sustainable. It is considered that the allocation of new housing on strategic sites that are outside Cambridge Centre and beyond the Green Belt, is not sustainable. This is due to the potential over reliance on the private vehicle to be able to access services, facilities and employment opportunities. The Sustainability Appraisal 2026 identifies this as a potential for concern of development ‘jumping’ the Green Belt, meaning some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which will result in disproportionate increases in vehicle travel. Therefore, the Development Strategy as proposed is not considered to meet the Plan’s Vision and the NPPF’s central premise of a sustainable pattern of development. The Plan is therefore unsound as it is not in accordance with national policy.

Reliance on New Settlements and Strategic Sites

2.5. NPPF Paragraph 36(c) requires plans to be effective and therefore deliverable over the plan period. Miller Homes considers the development strategy fails this test due to its reliance on new settlements and strategic sites, equating to an overdependence on long-term delivery and long lead in times. Whilst it is recognised that the Council has included these schemes to induce sustained growth beyond the initial 5-year housing supply period in accordance with paragraph 72(b) of the NPPF, it is a missed opportunity not to allocate smaller sites to increase headroom and produce a concrete supply regardless of the long lead times within the immediate 5-year period. Therefore, this approach fails to address the need for sustained growth across the plan period.

2.6. Within the new housing allocations, 12,550 are provided on five strategic sites varying in size from 1,000 to 3,950 dwellings. The evidence report Greater Cambridge Housing Development Strategy Topic paper Appendix 10: Housing trajectory (2026), outlines the lead-in times of strategic sites (200 dwellings and above) to be 6 years from allocation to first completions. Miller Homes considers these lead times to be overly ambitious and generalised and suggest that more clarity is needed regarding the site-specific factors regarding lead times and build out rates. This approach should take account of the current lead times facing developers, irrespective of past performance, alongside current viability constraints facing developers nationwide. Furthermore, there are often delays on strategic sites of this scale due site-specific constraints or external factors like the Government’s announcement that it will not be funding the Cambridge Waste Water Treatment Plant which has impacted the delivery of the North East Cambridge site.

2.7. Despite the Councils retaining confidence in this approach in the Housing Delivery Study (Addendum 2026 Update), more clarity is needed regarding the site-specific factors regarding build out rates and lead in times.

2.8. For instance, Cambridge East (Airport) is due to see first completions in 2032/33, on the Councils’ average 6-year lead in time, this would mean a planning application is submitted within the next year. On this assumption, determination and a Section 106 agreement would have to be completed within 2 to 3 years, with infrastructure, land assembly, conditions discharge, pre-commencement works and reserved matters approvals all completed for a start on site in no later than 2031/32. This is considered ambitious for the scale of the site, noting the existing occupiers and given the current market.

2.9. Similarly, the delivery rate is very high at 350dpa from 2035/36 to 2044/45. Whilst the Councils’ state that the 350dpa is a ‘peak’, this is contested given it is sustained for such a long period of time. The average over 13 years of delivery is still over 300dpa. It would be more appropriate to assume an average delivery rate based on evidence of past performance in Cambridgeshire.. For instance, Lichfield’s Start to Finish Report 2024 details the considerable range in delivery rates in Cambridgeshire. Table 1 sets out the mean build out rate (DPA) for 8 established strategic sites, each with more than four years of build out data. These sites have progressed through a range of economic climates, including periods of abundancy alongside times of crisis and flux (e.g. the 2008 financial crisis and the 2020 coronavirus pandemic).

Site Mean DPA
Great Kneighton (Clay Farm) 218.8
Cambourne (original new settlement) 188.0
Northstowe Phase 1 184.7
North West Cambridge 148.7
Upper Cambourne 105.6
Trumpington Meadows 96.4
Orchard Park 79.2
North Ely (Orchards Green) 62.3
Table 1: Mean build out rates across eight established strategic sites in Cambridgeshire

2.10. To this end, this data provides a robust and justified evidence base for assessing realistic delivery performance. The data indicates that large strategic sites (urban extensions and new settlements) have been built out at an average rate of 135.5 dpa and no site exceeds a 220 dpa average well below the forecasted 300dpa for new settlements or 350dpa for urban extensions. Therefore, Miller consider the forecasted rates need to be recalculated using the average dpa across these entirety of these sites rather than the peak when calculating housing delivery, to avoid overestimating future completions, factor in economic flux and ensure that assumptions are deliverable and justified against previous performance.




2.11. Therefore, Miller Homes does not support the paragraph 2 of Policy S/DS: Development Strategy in regard to overreliance on strategic sites. It is considered that this approach, fails to produce sufficient sites that can come forward both within the next 5 years and over the plan period. The plan is therefore, considered ineffective as it does not accord with paragraph 36(C) of the NPPF.

2.12. It is with this understanding that Miller Homes consider that additional sites should be allocated for the Plan to accord with the provision of deliverable and available sites as stipulated by NPPF Paragraph 72 and support a robust 5 year housing land supply position and guard against any potential delays that may arise with the strategic sites over the plan period.

Windfall allowance and the need for medium scale deliverable schemes

2.13. Paragraph 75 of the NPPF states that “where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply”. The Greater Cambridge Housing Delivery Study Addendum Update (2026) utilises historic data from 2006-2024 to base future trends. This has identified a delivery of 425 windfall dwellings per annum. In the review of expected future trends, national policy changes in relation to developing brownfield sites has been identified to highlight how it will be easier to bring brownfield sites forward. However, the assumption that windfall sites will be delivered on mainly brownfield sites is questioned. This is due to there being fewer opportunities as many sites have already been utilised, with a potential decrease in brownfield churn. Furthermore, in the Main Viability Report produced by Aspinall Verdi (2026) small brownfield sites have been identified as being susceptible to fluctuations and the potential of low viability meaning the Councils may have to take a more flexible approach to contributions

2.14. Furthermore, the Plan currently starts making an allowance for windfalls from 2029/30. However, the Plan is anticipated to be adopted in 2028. Whilst the current base takes account of commitments up to March 2026, and thus there is a 3-year gap between windfalls and commitments, the Councils will need to ensure that this is rolled forward as the Plan progresses. There is otherwise a danger of double counting completions from existing commitments and windfalls. This could reduce the supply in the first 5 years and the plan period by as much as 850 homes. For a plan adoption of 2028, windfalls should not be considered as a source of supply until 2031/32.

2.15. For these reasons, therefore, the assessment of the windfall allowance is not sufficiently compelling that it will continue to be a reliable source of supply.

Rural centres and Minor Rural Centres
2.16. Miller Homes does not support the part 3(b) of Policy S/DS: Development Strategy due to the failure to include active and/ or sustainable transport as a factor when determining service provision. This addition would support the vision for Cambridge reducing vehicle reliance and promoting sustainable patterns of development in line with NPPF paragraph 73.

2.17. Miller Homes consider that the policy should be reworded to include active travel links such as greenways, cycle paths and public rights of way to support connectivity to Cambridge and the trains stations rather than solely referring to public transport.


Housing and Landscape Evidence

2.18. It is noted that the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA – October 2025) assessed the Land South of Shelford Road, Fulbourn (Reference: 40501 / 115137). The HELAA raised concerns about the development of the site impacting the landscape character of the area and on key views to and from the village of Fulbourn, this view is disputed. A review of the Landscape Sensitivity Assessment has been undertaken and is included in appended ‘Representations (Landscape and Visual Issues)’ (Appendix 2). This assessment includes a set of views of Land South of Shelford Road, Fulbourn from the local highways and PRoWs, as well as a Screened Zone of Theoretical Visibility plan. These assessments conclude that the overwhelming majority of the nearby visual receptors and those in the wider countryside would not be affected or effects would be limited were the site at Land South of Shelford Road, Fulbourn to be allocated. The landscape sensitivity assessment supports the site as an appropriate site for development.

2.19. The site is also assessed within the Greater Cambridge Landscape Sensitivity Assessment (November 2021) as part of a larger Assessment Unit FUL05 of medium sensitivity to residential and mix-use developments. This assessment identifies that with medium landscape sensitivity any landscape character effects of the development of Land South of Shelford Road, Fulbourn Site would be moderated and therefore appropriate for allocation as an Edge of Cambridge site.

2.20. Therefore, it is considered that Land South of Shelford Road, Fulbourn is an appropriate Edge of Cambridge allocation that would provide a variety and choice of housing in a sustainable location.

Conclusion

Miller Homes considers that the Greater Cambridge Local Plan, in its current form, fails to meet the NPPF tests of soundness at Paragraph 36. Specifically:
• The Plan is not justified (NPPF Paragraph 36(b)) – the growth strategy relies on new settlements and strategic growth locations without adequate consideration of reasonable alternatives, including meeting the housing need in areas such as Fulbourn.
• The Plan is not effective (NPPF Paragraph 36(c)) – the reliance on new settlements and strategic sites with long lead-in times, supported by an assumption that lead times and build out will follow existing trends, creates an ineffective strategy that places the Councils’ immediate five-year housing land supply at risk. The Plan also fails to provide for deliverability over the plan period.

Accordingly, Miller Homes consider that, to address these soundness concerns, Land South of Shelford Road, Fulbourn be allocated within the Greater Cambridge Local Plan.

The site aligns closely with the Councils' Vision for Cambridge, occupies a sustainable location, close to Cambridge city and is capable of early delivery, and would maintain the vitality of Fulbourn. The Site would provide housing in a sustainable and suitable location supported by active travel, housing delivery and long-term place-making objectives.

Its allocation would increase flexibility within the housing strategy, strengthen the Plan's deliverability and make a meaningful contribution towards maintaining a robust five-year housing land supply upon adoption of the Local Plan.