Greater Cambridge Local Plan: Proposed Submission

1. Amend Policy S/DS and its supporting text to recognise expressly that small and medium-sized sites in sustainable villages will form a planned and meaningful component of the development strategy.

2. Review the spatial distribution of housing growth and provide a clear comparison with a reasonable alternative involving a greater contribution from Group Villages and other suitably serviced rural settlements.

3. Allocate additional small and medium-sized sites, including sites capable of contributing during the first five years of the Plan period.

4. Demonstrate separately how the Plan meets the national policy expectations sites of no more than one hectare, without relying upon an amalgamation of historic completions, existing commitments and unidentified windfalls. Also provide clear justification as to why the Council in its plan preparation is deviating so markedly from the NPPF.

5. Where the relevant targets are not met, identify the strong reasons relied upon, supported by proportionate and transparent evidence.

6. Review the relationship between planned housing and employment growth, particularly where new employment allocations are proposed in or adjoining rural settlements.

7. Reassess suitable promoted village sites as part of a coherent alternative portfolio, taking account of their cumulative contribution to delivery, housing choice, affordable housing, SME participation and rural vitality.

8. Introduce additional flexibility into the housing trajectory through a geographically and commercially diverse range of allocations with different lead-in periods, delivery models and infrastructure requirements.

9. Consider HELAA site 40323 alongside other suitable promoted sites as an example of land which may contribute to the necessary diversification of supply, subject to appropriate site-specific assessment and mitigation.

The principle of directing substantial growth towards Cambridge, the edge of Cambridge and appropriately located strategic growth areas is broadly supported. Those locations can make an important contribution towards meeting the development needs of Greater Cambridge. The soundness concern is therefore not founded upon an objection to strategic growth in principle. Rather, it arises from the degree to which the Plan concentrates future housing delivery within a relatively narrow range of large and complex locations, while assigning only a limited and largely residual role to small and medium-sized sites and sustainable rural settlements, an example being Over, which is identified as a Group Village within the settlement hierarchy. It is noted that whilst this representation focuses on the overall spatial strategy, our client has a direct interest in the Land north of Willingham Road, Over. As such our comments also focus on small/medium scale development sites.

With regard to the spatial strategy, it also risks overlooking the needs of communities towards the periphery of the Plan area. Not all residents will work in or travel to Cambridge, and sustainable settlements such as Over have an important role in meeting wider housing needs and supporting a more balanced distribution of growth across Greater Cambridge. The Council’s spatial search sequence prioritises opportunities within Cambridge, followed by the edge of Cambridge, new settlements and then better-served villages. Although such a sequence may represent a legitimate starting point for assessing broad spatial options, it does not itself demonstrate that the distribution ultimately selected is the most appropriate strategy. A sequential search process should not become a rigid hierarchy under which otherwise sustainable opportunities are discounted merely because sufficient theoretical capacity has first been identified within locations appearing earlier in the sequence. The strategy offers no flexibility for changing circumstances.

The relevant question for soundness is not simply whether the preferred strategic locations are capable of accommodating development. It is whether the overall distribution represents an appropriate, balanced and deliverable strategy when compared with the reasonable alternatives. That requires consideration of the cumulative benefits of a more diverse portfolio, including the contribution that smaller and medium-sized sites in sustainable settlements could make to early delivery, market choice, affordable housing provision, rural vitality and the resilience of the housing trajectory.

The Plan has not adequately demonstrated why these benefits have been afforded comparatively limited weight. Nor has it demonstrated why a strategy incorporating a greater proportion of suitably located small and medium-sized allocations would not represent a more balanced and effective approach.


THE SPATIAL STRATEGY IS NOT JUSTIFIED

To be justified, the Plan must represent an appropriate strategy, taking reasonable alternatives into account and being based upon proportionate evidence. The Council has identified and assessed a range of development opportunities, but the existence of an extensive evidence base does not, by itself, establish that the strategy selected is the most appropriate one.

The Plan’s approach appears to proceed from the broad assumption that the concentration of development at Cambridge, its edge and strategic growth locations is inherently preferable to distributing a modestly greater proportion of growth to sustainable villages. That proposition requires more careful examination. Sustainability is not determined solely by settlement size or by a settlement’s position within a strategic search sequence. It also depends upon the relationship of development to existing services, employment, public transport, community infrastructure and the capacity of individual places to accommodate proportionate growth.

The Plan should therefore distinguish between rural locations that are poorly served, physically constrained or inadequately related to existing settlements and those where modest growth could be accommodated sustainably. A strategy which treats village development primarily as a residual element can risk overlooking meaningful differences between settlements and between individual development opportunities. It also fails to recognise the benefits that growth can have to the viability of local services and facilities. This is particularly relevant in the context of demographic change within rural Cambridgeshire. Census 2021 analysis undertaken by Cambridgeshire & Peterborough Combined Authority (Research Team, Business Intelligence, 2022) identifies substantially greater growth in the population aged 65 and over across the County's rural districts than in younger and working-age groups. A strategy which places excessive restraint on otherwise sustainable village growth therefore risks reinforcing, rather than responding to, an increasingly unbalanced demographic profile.

The proposed restrictions applicable to Group Villages illustrate the concern. Policy S/SH generally limits residential development within Group Villages to an indicative maximum of eight dwellings, with schemes of up to around 15 dwellings only contemplated exceptionally where they would make the best use of a single brownfield site. In practice, this provides very limited scope for planned and proportionate growth at otherwise sustainable villages, including on suitable land immediately adjoining existing settlement boundaries.

This is not a new approach. It substantially continues the restrictive framework established by Policy S/10 of the adopted South Cambridgeshire Local Plan 2018, which permits residential development of up to eight dwellings within Group Village development frameworks. The proposed strategy therefore carries forward a long-established constraint on the scale and location of development within Group Villages, rather than providing greater flexibility to accommodate proportionate growth where suitable and deliverable opportunities arise.

Given that this approach has already operated through successive plan-making, it is reasonable to question whether simply carrying forward broadly the same thresholds provides a sufficiently responsive basis for meeting housing needs over a further plan period, particularly where opportunities within established development frameworks are necessarily finite.

The strategy therefore risks applying broad restraint without sufficiently differentiating between unsuitable countryside development and well-related village-edge opportunities. A more proportionate approach would identify the better-performing rural settlements and then select the most sustainable and deliverable opportunities associated with them. This would not require unrestricted rural growth, nor would it undermine the principal focus upon Cambridge and the strategic locations. It would instead introduce greater balance into the selected strategy.

The Council should also demonstrate that reasonable alternatives involving a larger contribution from small and medium-sized sites and Group Villages were considered on a genuinely comparable basis. It is insufficient merely to record that promoted sites were assessed. The soundness evidence should explain whether a coherent alternative distribution incorporating a greater number of such sites was tested, how its sustainability and delivery implications compared with the preferred strategy, and why it was rejected.

Without that comparative assessment, it is not clear that the Plan’s limited role for sustainable villages results from a balanced evaluation of alternatives, rather than from the prior application of a search sequence which inherently favours large strategic locations.


INSUFFICIENT PROVISION FOR SMALL AND MEDIUM-SIZED SITES

A central weakness in the strategy is the limited planned role assigned to small and medium-sized housing sites.

The Plan’s evidence refers to completions, commitments, proposed allocations and anticipated windfall development when assessing the contribution of smaller sites. However, these components are not interchangeable. Historic completions concern development already delivered. Commitments arise from decisions made before the adoption of the new Plan. Windfalls are, by definition, not specifically identified; they are not confined to small and medium-sized sites and can also be very large in scale. Windfall provision cannot, therefore, be relied upon to justify the Plan’s approach to small and medium-sized sites. Together, these sources may contribute towards housing supply, but they do not remove the need for the Plan itself to allocate an appropriately diverse portfolio of new sites.

A district-wide numerical calculation also does not demonstrate that the spatial distribution of small and medium-sized sites is appropriate. It cannot establish whether those sites are spread across a suitable range of settlements, whether they will support identified rural communities, or whether they will provide a reliable source of housing throughout the Plan period.

The strategic purpose of allocating smaller and medium-sized sites extends beyond meeting an aggregate numerical target. Such allocations can:
• provide an earlier contribution to housing delivery;
• broaden the range of developers and delivery models;
• create opportunities suitable for SME housebuilders;
• increase market choice and competition;
• support delivery across different housing market areas;
• provide additional opportunities for affordable housing;
• sustain services and facilities in existing communities; and
• provide a complementary source of supply where strategic allocations experience delay.

These are benefits of the portfolio as a whole. The case for diversification does not depend upon proving that any particular strategic allocation will fail. A sound plan should anticipate the possibility that some large sites will progress more slowly than expected and should establish sufficient flexibility to respond to that risk.

As detailed within the Consultation Statement, Appendix 6: Response to Representations, “Strategic and smaller scale development” at pp.112–115, representations raised concern that the strategy places an over-reliance on a few large strategic sites, that the Plan should include a greater mix of smaller and medium-sized sites, and that the development strategy does not adequately provide for rural and village growth. The representations specifically identify the benefits of smaller sites for housing delivery, five-year housing land supply, SME housebuilders, housing choice and meeting local housing needs. Nevertheless, no additional allocations were introduced in the Rest of the Rural Area at the Regulation 19 stage.


THE STRATEGY IS NOT EFFECTIVE

The effectiveness of the Plan depends not only upon the total capacity identified but also upon the timing, complexity and certainty of delivery.

A substantial proportion of the strategy relies upon large development locations and infrastructure programmes requiring coordination between landowners, developers, infrastructure providers, statutory bodies and public authorities. The Council’s own material acknowledges dependencies relating to transport schemes, public transport corridors, water supply, wastewater infrastructure and other utilities. It also identifies related risks to housing delivery and the maintenance of a five-year housing land supply.

The existence of these dependencies does not necessarily mean that the strategic allocations are undeliverable. It does, however, make flexibility and contingency an essential component of the strategy. A plan which concentrates delivery within a relatively small number of large allocations will be more exposed to changes in infrastructure programming, statutory approvals, funding, viability, land assembly and market conditions.

The Council should therefore demonstrate that the housing trajectory has been subject to appropriate and robust testing. In particular, the evidence should explain how the Plan would respond if one or more major allocations were delayed, if infrastructure were delivered later than assumed, with particular regard to adequate water supplies, or if build-out rates were lower than anticipated. The availability of a theoretical housing buffer would not necessarily resolve these concerns if the buffer itself is concentrated within the same categories of complex or infrastructure-dependent development.

A more diverse portfolio of allocated sites would materially improve effectiveness. Small and medium-sized developments will not replace strategic locations and cannot individually deliver the same scale of infrastructure or housing. Their value lies in their ability to provide multiple, complementary sources of supply with differing delivery characteristics. Collectively, they can reduce the consequences of delay at any one location and increase the likelihood that housing will be delivered at the time envisaged.

The Plan should therefore allocate a meaningful range of smaller and medium-sized sites capable of contributing during the early and middle parts of the Plan period. The Plan should therefore allocate a meaningful range of small and medium-sized sites capable of contributing during the early and middle parts of the Plan period, as such sites can typically come forward within the first five years. Such sites can provide a flexible and responsive source of housing supply, particularly at the point when maintaining a robust five-year housing land supply and confidence in the overall housing trajectory is most important. Their allocation would supplement, rather than displace, the strategic sites, broadening the sources of housing delivery and providing greater resilience should delivery on larger sites be delayed or fall below anticipated rates. This would provide greater confidence that the housing requirement can be met consistently throughout the Plan period.


THE STRATEGY IS NOT CONSISTENT WITH NATIONAL POLICY

Chapter 6 (Delivering a sufficient supply of homes) of the 2026 National Planning Policy Framework (NPPF) requires local plans to secure an appropriate supply and mix of sites and to maintain a diverse portfolio of development opportunities.

Paragraph 73 of the NPPF states that “small and medium sized sites can make an important contribution to meeting the housing requirement of an area.” Paragraph 73(a) requires land to be allocated to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless strong reasons demonstrate that those targets cannot be achieved.

The provision in the NPPF establishes an express expectation that small and medium-sized sites should form a meaningful part of the planned housing strategy. If the Council does not propose to meet either target, it must identify clear and evidenced reasons explaining why achievement is not reasonably possible.

A general preference for larger strategic growth locations would not, without further evidence, amount to a strong reason. Nor would a calculation which combines past completions, existing commitments and unidentified future windfalls necessarily demonstrate that the Plan’s allocation strategy is consistent with the intended purpose of the national policy. The relevant requirement concerns the allocation of land and therefore seeks a planned, identifiable and deliverable contribution from sites within the specified size categories.

The relevant question is therefore whether the Council has robustly tested whether the targets could reasonably be achieved through the site assessment and spatial strategy process. If suitable opportunities exist but have not been allocated because growth has instead been concentrated within larger strategic locations, that is a consequence of the chosen strategy rather than, in itself, a strong reason for departing from national policy. The preferred spatial strategy should not effectively become the justification for its own departure from the national policy expectation.

The Council should accordingly identify:
1. the amount of the housing requirement proposed to be accommodated on allocated sites of no more than one hectare;
2. the amount of the housing requirement proposed to be accommodated on small and medium-sized sites;
3. the spatial distribution of those allocations;
4. the anticipated phasing of their delivery;
5. the contribution they make to rural communities and SME delivery; and
6. any strong reasons relied upon where the relevant targets are not achieved.

This information should be transparent within the Plan and its supporting evidence. It should not be necessary to aggregate unrelated categories of supply to determine whether the underlying policy objective has been satisfied.

National policy also supports the allocation of sites which sustain and enhance rural communities and enable villages to grow and thrive, particularly where development would support local services. The Plan’s tightly constrained approach to village growth does not give sufficient practical effect to that objective.

Windfall development, rural exception sites and neighbourhood plans cannot be treated as complete substitutes for strategic allocations. Windfalls provide limited certainty over location, timing and scale and are a finite resource, particularly in areas of high demand. Rural exception sites address a particular form of housing need and are not equivalent to general housing allocations. Neighbourhood planning is voluntary and cannot be relied upon to remedy a deficiency in the strategic distribution established through the Local Plan.

The Local Plan itself must therefore establish a positive framework for proportionate rural growth.


RURAL VITALITY AND THE SETTLEMENT HIERARCHY

The settlement hierarchy should provide a basis for directing development to locations with an appropriate level of services, accessibility and community infrastructure. It should not operate as an inflexible limit which prevents sustainable opportunities from being considered on their individual merits.

Many rural settlements perform several functions simultaneously. They provide homes, employment, schools, shops, community facilities and public transport connections, while also supporting a wider rural hinterland. The long-term vitality of such settlements may depend upon a proportionate degree of population and housing growth.

Restricting planned development too severely can itself have sustainability consequences. It may reduce opportunities to meet locally arising housing needs, constrain the provision of affordable housing and limit the customer base available to support local services. The assessment of sustainability should therefore consider both the impacts of additional development and the consequences of an absence of planned growth.

The Plan should identify those villages which are capable of accommodating a proportionate level of development, taking account of:
• the availability and accessibility of services and facilities;
• diverse and balanced community needs;
• opportunities for walking, cycling and public transport;
• the existence of local employment;
• the physical relationship between promoted land and the settlement;
• landscape and settlement character;
• environmental and infrastructure constraints;
• the ability to secure mitigation; and
• the availability and achievability of individual sites.

This would allow growth to be directed selectively towards the most suitable opportunities rather than applying a broad presumption against village-edge allocations.


RELATIONSHIP BETWEEN HOMES AND EMPLOYMENT

The distribution of housing should also be considered alongside the Plan’s employment strategy.
Where the Plan supports new or expanded employment opportunities in rural settlements, it should consider whether an appropriate level of additional housing is needed to maintain a coherent relationship between homes and jobs. This does not require housing and employment growth to be matched arithmetically. It does require the spatial strategy to avoid an approach in which economic development is supported in rural locations while the occupation and growth of those communities are tightly restricted.

Over illustrates this wider point. The Plan proposes an extension to the Norman Way industrial estate, as detailed within Policy S/RRA/NW. The allocation seeks to provide approximately 6,100m2 of employment floorspace, while offering no comparable planned housing opportunity within the village. The example indicates that the Council considers the settlement capable of accommodating planned economic growth, but the Plan does not clearly explain why a proportionate housing allocation would be inconsistent with the same spatial objectives. A similar issue arises with the proposed allocations at the A14 Swavesey Services under Policies S/RRA/SCS and S/RRA/BBP, where substantial employment growth is proposed with limited corresponding housing provision. This again risks an imbalance between jobs and homes and strengthens the case for additional housing opportunities in nearby rural settlements.

This is not advanced as a site-specific argument applicable only to Over. It illustrates a broader need for the Plan to consider the relationship between planned employment, housing, local services and travel patterns across the rural area.


EVIDENCE OF REASONABLE ALTERNATIVES

The Council’s land availability assessment should inform, but not predetermine, the allocation process. Where sites are found to be available and achievable and are not subject to overriding constraints, they should be considered as part of reasonable alternative spatial strategies.

An ‘Amber’ assessment should not automatically be treated as equivalent to unsuitability. It may identify a need for further evidence, a reduced capacity, mitigation or site-specific policy criteria. Where those matters are capable of resolution, the site may remain a credible allocation option.

Land north of Willingham Road, Over, identified as HELAA site 40323, provides one example, as assessed within the Greater Cambridge HELAA (2021), Appendix 4. The assessment identifies a 1.94-hectare site adjoining a Group Village, with ‘Green’ availability and achievability assessments and anticipated delivery within the first five years. Its overall suitability is assessed as ‘Amber’, reflecting landscape, ecology and highway matters requiring further assessment. These matters are not identified as fundamental constraints to development and are capable of being addressed through appropriate site-specific assessment, mitigation and scheme design, including sensitive landscape treatment, ecological protection and enhancement measures, and suitable access and highway arrangements.

The purpose of referring to this site is not to make the wider strategic objection dependent upon its allocation. Rather, it demonstrates that promoted opportunities exist within the size category supported by national policy and that some could contribute to a more diverse, geographically balanced and resilient housing supply. The Council should reassess these opportunities collectively as part of a reasonable alternative involving a greater planned contribution from small and medium-sized developments and sustainable villages.


OVERALL SOUNDNESS CONCLUSION

The Proposed Submission Plan has not demonstrated that its highly concentrated distribution of growth represents the most appropriate strategy when compared with a more balanced alternative.

The strategy is not justified because the evidence does not adequately demonstrate why sustainable villages and small and medium-sized sites should play such a limited role, or why an alternative distribution incorporating a greater number of those sites was rejected. Where sites have been promoted and assessed as capable of contributing, they should be collectively tested as an alternative portfolio. It is insufficient to reject them individually without evaluating the cumulative effect of a more distributed strategy.

It is not effective because the concentration of housing delivery within large and complex locations exposes the trajectory to common infrastructure, phasing, viability and market risks without providing a sufficiently diverse supply of complementary allocations.

It is not consistent with national policy because it does not give sufficient practical effect to the requirement to allocate a meaningful proportion of housing on small and medium-sized sites or to support rural communities by enabling suitable villages to grow and thrive.

These concerns do not require the abandonment or substantial reduction of the Plan’s strategic locations. They require the strategy to be broadened so that those locations are complemented by an appropriate selection of deliverable small and medium-sized allocations distributed across sustainable settlements.

1. Amend Policy S/SH and the relevant settlement policies so that the settlement hierarchy facilitates proportionate planned growth at sustainable villages rather than limiting their role principally to windfalls, exception sites and neighbourhood planning.

2. Review the spatial distribution of housing growth and provide a clear comparison with a reasonable alternative involving a greater contribution from Group Villages and other suitably serviced rural settlements.

3. Allocate additional small and medium-sized sites, including sites capable of contributing during the first five years of the Plan period.

4. Demonstrate separately how the Plan meets the national policy expectations sites of no more than one hectare, without relying upon an amalgamation of historic completions, existing commitments and unidentified windfalls. Also provide clear justification as to why the Council in its plan preparation is deviating so markedly from the NPPF.

5. Where the relevant targets are not met, identify the strong reasons relied upon, supported by proportionate and transparent evidence.

6. Review the relationship between planned housing and employment growth, particularly where new employment allocations are proposed in or adjoining rural settlements.

7. Reassess suitable promoted village sites as part of a coherent alternative portfolio, taking account of their cumulative contribution to delivery, housing choice, affordable housing, SME participation and rural vitality.

8. Introduce additional flexibility into the housing trajectory through a geographically and commercially diverse range of allocations with different lead-in periods, delivery models and infrastructure requirements.

9. Consider HELAA site 40323 alongside other suitable promoted sites as an example of land which may contribute to the necessary diversification of supply, subject to appropriate site-specific assessment and mitigation.

The principle of directing substantial growth towards Cambridge, the edge of Cambridge and appropriately located strategic growth areas is broadly supported. Those locations can make an important contribution towards meeting the development needs of Greater Cambridge. The soundness concern is therefore not founded upon an objection to strategic growth in principle. Rather, it arises from the degree to which the Plan concentrates future housing delivery within a relatively narrow range of large and complex locations, while assigning only a limited and largely residual role to small and medium-sized sites and sustainable rural settlements, an example being Over, which is identified as a Group Village within the settlement hierarchy. It is noted that whilst this representation focuses on the overall spatial strategy, our client has a direct interest in the Land north of Willingham Road, Over. As such our comments also focus on small/medium scale development sites.

With regard to the spatial strategy, it also risks overlooking the needs of communities towards the periphery of the Plan area. Not all residents will work in or travel to Cambridge, and sustainable settlements such as Over have an important role in meeting wider housing needs and supporting a more balanced distribution of growth across Greater Cambridge. The Council’s spatial search sequence prioritises opportunities within Cambridge, followed by the edge of Cambridge, new settlements and then better-served villages. Although such a sequence may represent a legitimate starting point for assessing broad spatial options, it does not itself demonstrate that the distribution ultimately selected is the most appropriate strategy. A sequential search process should not become a rigid hierarchy under which otherwise sustainable opportunities are discounted merely because sufficient theoretical capacity has first been identified within locations appearing earlier in the sequence. The strategy offers no flexibility for changing circumstances.

The relevant question for soundness is not simply whether the preferred strategic locations are capable of accommodating development. It is whether the overall distribution represents an appropriate, balanced and deliverable strategy when compared with the reasonable alternatives. That requires consideration of the cumulative benefits of a more diverse portfolio, including the contribution that smaller and medium-sized sites in sustainable settlements could make to early delivery, market choice, affordable housing provision, rural vitality and the resilience of the housing trajectory.

The Plan has not adequately demonstrated why these benefits have been afforded comparatively limited weight. Nor has it demonstrated why a strategy incorporating a greater proportion of suitably located small and medium-sized allocations would not represent a more balanced and effective approach.


THE SPATIAL STRATEGY IS NOT JUSTIFIED

To be justified, the Plan must represent an appropriate strategy, taking reasonable alternatives into account and being based upon proportionate evidence. The Council has identified and assessed a range of development opportunities, but the existence of an extensive evidence base does not, by itself, establish that the strategy selected is the most appropriate one.

The Plan’s approach appears to proceed from the broad assumption that the concentration of development at Cambridge, its edge and strategic growth locations is inherently preferable to distributing a modestly greater proportion of growth to sustainable villages. That proposition requires more careful examination. Sustainability is not determined solely by settlement size or by a settlement’s position within a strategic search sequence. It also depends upon the relationship of development to existing services, employment, public transport, community infrastructure and the capacity of individual places to accommodate proportionate growth.

The Plan should therefore distinguish between rural locations that are poorly served, physically constrained or inadequately related to existing settlements and those where modest growth could be accommodated sustainably. A strategy which treats village development primarily as a residual element can risk overlooking meaningful differences between settlements and between individual development opportunities. It also fails to recognise the benefits that growth can have to the viability of local services and facilities. This is particularly relevant in the context of demographic change within rural Cambridgeshire. Census 2021 analysis undertaken by Cambridgeshire & Peterborough Combined Authority (Research Team, Business Intelligence, 2022) identifies substantially greater growth in the population aged 65 and over across the County's rural districts than in younger and working-age groups. A strategy which places excessive restraint on otherwise sustainable village growth therefore risks reinforcing, rather than responding to, an increasingly unbalanced demographic profile.

The proposed restrictions applicable to Group Villages illustrate the concern. Policy S/SH generally limits residential development within Group Villages to an indicative maximum of eight dwellings, with schemes of up to around 15 dwellings only contemplated exceptionally where they would make the best use of a single brownfield site. In practice, this provides very limited scope for planned and proportionate growth at otherwise sustainable villages, including on suitable land immediately adjoining existing settlement boundaries.

This is not a new approach. It substantially continues the restrictive framework established by Policy S/10 of the adopted South Cambridgeshire Local Plan 2018, which permits residential development of up to eight dwellings within Group Village development frameworks. The proposed strategy therefore carries forward a long-established constraint on the scale and location of development within Group Villages, rather than providing greater flexibility to accommodate proportionate growth where suitable and deliverable opportunities arise.

Given that this approach has already operated through successive plan-making, it is reasonable to question whether simply carrying forward broadly the same thresholds provides a sufficiently responsive basis for meeting housing needs over a further plan period, particularly where opportunities within established development frameworks are necessarily finite.

The strategy therefore risks applying broad restraint without sufficiently differentiating between unsuitable countryside development and well-related village-edge opportunities. A more proportionate approach would identify the better-performing rural settlements and then select the most sustainable and deliverable opportunities associated with them. This would not require unrestricted rural growth, nor would it undermine the principal focus upon Cambridge and the strategic locations. It would instead introduce greater balance into the selected strategy.

The Council should also demonstrate that reasonable alternatives involving a larger contribution from small and medium-sized sites and Group Villages were considered on a genuinely comparable basis. It is insufficient merely to record that promoted sites were assessed. The soundness evidence should explain whether a coherent alternative distribution incorporating a greater number of such sites was tested, how its sustainability and delivery implications compared with the preferred strategy, and why it was rejected.

Without that comparative assessment, it is not clear that the Plan’s limited role for sustainable villages results from a balanced evaluation of alternatives, rather than from the prior application of a search sequence which inherently favours large strategic locations.


INSUFFICIENT PROVISION FOR SMALL AND MEDIUM-SIZED SITES

A central weakness in the strategy is the limited planned role assigned to small and medium-sized housing sites.

The Plan’s evidence refers to completions, commitments, proposed allocations and anticipated windfall development when assessing the contribution of smaller sites. However, these components are not interchangeable. Historic completions concern development already delivered. Commitments arise from decisions made before the adoption of the new Plan. Windfalls are, by definition, not specifically identified; they are not confined to small and medium-sized sites and can also be very large in scale. Windfall provision cannot, therefore, be relied upon to justify the Plan’s approach to small and medium-sized sites. Together, these sources may contribute towards housing supply, but they do not remove the need for the Plan itself to allocate an appropriately diverse portfolio of new sites.

A district-wide numerical calculation also does not demonstrate that the spatial distribution of small and medium-sized sites is appropriate. It cannot establish whether those sites are spread across a suitable range of settlements, whether they will support identified rural communities, or whether they will provide a reliable source of housing throughout the Plan period.

The strategic purpose of allocating smaller and medium-sized sites extends beyond meeting an aggregate numerical target. Such allocations can:
• provide an earlier contribution to housing delivery;
• broaden the range of developers and delivery models;
• create opportunities suitable for SME housebuilders;
• increase market choice and competition;
• support delivery across different housing market areas;
• provide additional opportunities for affordable housing;
• sustain services and facilities in existing communities; and
• provide a complementary source of supply where strategic allocations experience delay.

These are benefits of the portfolio as a whole. The case for diversification does not depend upon proving that any particular strategic allocation will fail. A sound plan should anticipate the possibility that some large sites will progress more slowly than expected and should establish sufficient flexibility to respond to that risk.

As detailed within the Consultation Statement, Appendix 6: Response to Representations, “Strategic and smaller scale development” at pp.112–115, representations raised concern that the strategy places an over-reliance on a few large strategic sites, that the Plan should include a greater mix of smaller and medium-sized sites, and that the development strategy does not adequately provide for rural and village growth. The representations specifically identify the benefits of smaller sites for housing delivery, five-year housing land supply, SME housebuilders, housing choice and meeting local housing needs. Nevertheless, no additional allocations were introduced in the Rest of the Rural Area at the Regulation 19 stage.


THE STRATEGY IS NOT EFFECTIVE

The effectiveness of the Plan depends not only upon the total capacity identified but also upon the timing, complexity and certainty of delivery.

A substantial proportion of the strategy relies upon large development locations and infrastructure programmes requiring coordination between landowners, developers, infrastructure providers, statutory bodies and public authorities. The Council’s own material acknowledges dependencies relating to transport schemes, public transport corridors, water supply, wastewater infrastructure and other utilities. It also identifies related risks to housing delivery and the maintenance of a five-year housing land supply.

The existence of these dependencies does not necessarily mean that the strategic allocations are undeliverable. It does, however, make flexibility and contingency an essential component of the strategy. A plan which concentrates delivery within a relatively small number of large allocations will be more exposed to changes in infrastructure programming, statutory approvals, funding, viability, land assembly and market conditions.

The Council should therefore demonstrate that the housing trajectory has been subject to appropriate and robust testing. In particular, the evidence should explain how the Plan would respond if one or more major allocations were delayed, if infrastructure were delivered later than assumed, with particular regard to adequate water supplies, or if build-out rates were lower than anticipated. The availability of a theoretical housing buffer would not necessarily resolve these concerns if the buffer itself is concentrated within the same categories of complex or infrastructure-dependent development.

A more diverse portfolio of allocated sites would materially improve effectiveness. Small and medium-sized developments will not replace strategic locations and cannot individually deliver the same scale of infrastructure or housing. Their value lies in their ability to provide multiple, complementary sources of supply with differing delivery characteristics. Collectively, they can reduce the consequences of delay at any one location and increase the likelihood that housing will be delivered at the time envisaged.

The Plan should therefore allocate a meaningful range of smaller and medium-sized sites capable of contributing during the early and middle parts of the Plan period. The Plan should therefore allocate a meaningful range of small and medium-sized sites capable of contributing during the early and middle parts of the Plan period, as such sites can typically come forward within the first five years. Such sites can provide a flexible and responsive source of housing supply, particularly at the point when maintaining a robust five-year housing land supply and confidence in the overall housing trajectory is most important. Their allocation would supplement, rather than displace, the strategic sites, broadening the sources of housing delivery and providing greater resilience should delivery on larger sites be delayed or fall below anticipated rates. This would provide greater confidence that the housing requirement can be met consistently throughout the Plan period.


THE STRATEGY IS NOT CONSISTENT WITH NATIONAL POLICY

Chapter 6 (Delivering a sufficient supply of homes) of the 2026 National Planning Policy Framework (NPPF) requires local plans to secure an appropriate supply and mix of sites and to maintain a diverse portfolio of development opportunities.

Paragraph 73 of the NPPF states that “small and medium sized sites can make an important contribution to meeting the housing requirement of an area.” Paragraph 73(a) requires land to be allocated to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless strong reasons demonstrate that those targets cannot be achieved.

The provision in the NPPF establishes an express expectation that small and medium-sized sites should form a meaningful part of the planned housing strategy. If the Council does not propose to meet either target, it must identify clear and evidenced reasons explaining why achievement is not reasonably possible.

A general preference for larger strategic growth locations would not, without further evidence, amount to a strong reason. Nor would a calculation which combines past completions, existing commitments and unidentified future windfalls necessarily demonstrate that the Plan’s allocation strategy is consistent with the intended purpose of the national policy. The relevant requirement concerns the allocation of land and therefore seeks a planned, identifiable and deliverable contribution from sites within the specified size categories.

The relevant question is therefore whether the Council has robustly tested whether the targets could reasonably be achieved through the site assessment and spatial strategy process. If suitable opportunities exist but have not been allocated because growth has instead been concentrated within larger strategic locations, that is a consequence of the chosen strategy rather than, in itself, a strong reason for departing from national policy. The preferred spatial strategy should not effectively become the justification for its own departure from the national policy expectation.

The Council should accordingly identify:
1. the amount of the housing requirement proposed to be accommodated on allocated sites of no more than one hectare;
2. the amount of the housing requirement proposed to be accommodated on small and medium-sized sites;
3. the spatial distribution of those allocations;
4. the anticipated phasing of their delivery;
5. the contribution they make to rural communities and SME delivery; and
6. any strong reasons relied upon where the relevant targets are not achieved.

This information should be transparent within the Plan and its supporting evidence. It should not be necessary to aggregate unrelated categories of supply to determine whether the underlying policy objective has been satisfied.

National policy also supports the allocation of sites which sustain and enhance rural communities and enable villages to grow and thrive, particularly where development would support local services. The Plan’s tightly constrained approach to village growth does not give sufficient practical effect to that objective.

Windfall development, rural exception sites and neighbourhood plans cannot be treated as complete substitutes for strategic allocations. Windfalls provide limited certainty over location, timing and scale and are a finite resource, particularly in areas of high demand. Rural exception sites address a particular form of housing need and are not equivalent to general housing allocations. Neighbourhood planning is voluntary and cannot be relied upon to remedy a deficiency in the strategic distribution established through the Local Plan.

The Local Plan itself must therefore establish a positive framework for proportionate rural growth.


RURAL VITALITY AND THE SETTLEMENT HIERARCHY

The settlement hierarchy should provide a basis for directing development to locations with an appropriate level of services, accessibility and community infrastructure. It should not operate as an inflexible limit which prevents sustainable opportunities from being considered on their individual merits.

Many rural settlements perform several functions simultaneously. They provide homes, employment, schools, shops, community facilities and public transport connections, while also supporting a wider rural hinterland. The long-term vitality of such settlements may depend upon a proportionate degree of population and housing growth.

Restricting planned development too severely can itself have sustainability consequences. It may reduce opportunities to meet locally arising housing needs, constrain the provision of affordable housing and limit the customer base available to support local services. The assessment of sustainability should therefore consider both the impacts of additional development and the consequences of an absence of planned growth.

The Plan should identify those villages which are capable of accommodating a proportionate level of development, taking account of:
• the availability and accessibility of services and facilities;
• diverse and balanced community needs;
• opportunities for walking, cycling and public transport;
• the existence of local employment;
• the physical relationship between promoted land and the settlement;
• landscape and settlement character;
• environmental and infrastructure constraints;
• the ability to secure mitigation; and
• the availability and achievability of individual sites.

This would allow growth to be directed selectively towards the most suitable opportunities rather than applying a broad presumption against village-edge allocations.


RELATIONSHIP BETWEEN HOMES AND EMPLOYMENT

The distribution of housing should also be considered alongside the Plan’s employment strategy.
Where the Plan supports new or expanded employment opportunities in rural settlements, it should consider whether an appropriate level of additional housing is needed to maintain a coherent relationship between homes and jobs. This does not require housing and employment growth to be matched arithmetically. It does require the spatial strategy to avoid an approach in which economic development is supported in rural locations while the occupation and growth of those communities are tightly restricted.

Over illustrates this wider point. The Plan proposes an extension to the Norman Way industrial estate, as detailed within Policy S/RRA/NW. The allocation seeks to provide approximately 6,100m2 of employment floorspace, while offering no comparable planned housing opportunity within the village. The example indicates that the Council considers the settlement capable of accommodating planned economic growth, but the Plan does not clearly explain why a proportionate housing allocation would be inconsistent with the same spatial objectives. A similar issue arises with the proposed allocations at the A14 Swavesey Services under Policies S/RRA/SCS and S/RRA/BBP, where substantial employment growth is proposed with limited corresponding housing provision. This again risks an imbalance between jobs and homes and strengthens the case for additional housing opportunities in nearby rural settlements.

This is not advanced as a site-specific argument applicable only to Over. It illustrates a broader need for the Plan to consider the relationship between planned employment, housing, local services and travel patterns across the rural area.


EVIDENCE OF REASONABLE ALTERNATIVES

The Council’s land availability assessment should inform, but not predetermine, the allocation process. Where sites are found to be available and achievable and are not subject to overriding constraints, they should be considered as part of reasonable alternative spatial strategies.

An ‘Amber’ assessment should not automatically be treated as equivalent to unsuitability. It may identify a need for further evidence, a reduced capacity, mitigation or site-specific policy criteria. Where those matters are capable of resolution, the site may remain a credible allocation option.

Land north of Willingham Road, Over, identified as HELAA site 40323, provides one example, as assessed within the Greater Cambridge HELAA (2021), Appendix 4. The assessment identifies a 1.94-hectare site adjoining a Group Village, with ‘Green’ availability and achievability assessments and anticipated delivery within the first five years. Its overall suitability is assessed as ‘Amber’, reflecting landscape, ecology and highway matters requiring further assessment. These matters are not identified as fundamental constraints to development and are capable of being addressed through appropriate site-specific assessment, mitigation and scheme design, including sensitive landscape treatment, ecological protection and enhancement measures, and suitable access and highway arrangements.

The purpose of referring to this site is not to make the wider strategic objection dependent upon its allocation. Rather, it demonstrates that promoted opportunities exist within the size category supported by national policy and that some could contribute to a more diverse, geographically balanced and resilient housing supply. The Council should reassess these opportunities collectively as part of a reasonable alternative involving a greater planned contribution from small and medium-sized developments and sustainable villages.


OVERALL SOUNDNESS CONCLUSION

The Proposed Submission Plan has not demonstrated that its highly concentrated distribution of growth represents the most appropriate strategy when compared with a more balanced alternative.

The strategy is not justified because the evidence does not adequately demonstrate why sustainable villages and small and medium-sized sites should play such a limited role, or why an alternative distribution incorporating a greater number of those sites was rejected. Where sites have been promoted and assessed as capable of contributing, they should be collectively tested as an alternative portfolio. It is insufficient to reject them individually without evaluating the cumulative effect of a more distributed strategy.

It is not effective because the concentration of housing delivery within large and complex locations exposes the trajectory to common infrastructure, phasing, viability and market risks without providing a sufficiently diverse supply of complementary allocations.

It is not consistent with national policy because it does not give sufficient practical effect to the requirement to allocate a meaningful proportion of housing on small and medium-sized sites or to support rural communities by enabling suitable villages to grow and thrive.

These concerns do not require the abandonment or substantial reduction of the Plan’s strategic locations. They require the strategy to be broadened so that those locations are complemented by an appropriate selection of deliverable small and medium-sized allocations distributed across sustainable settlements.

1. Amend Policy S/DS and its supporting text to recognise expressly that small and medium-sized sites in sustainable villages will form a planned and meaningful component of the development strategy.

2. Review the spatial distribution of housing growth and provide a clear comparison with a reasonable alternative involving a greater contribution from Group Villages and other suitably serviced rural settlements.

3. Allocate additional small and medium-sized sites, including sites capable of contributing during the first five years of the Plan period.

4. Demonstrate separately how the Plan meets the national policy expectations sites of no more than one hectare, without relying upon an amalgamation of historic completions, existing commitments and unidentified windfalls. Also provide clear justification as to why the Council in its plan preparation is deviating so markedly from the NPPF.

5. Where the relevant targets are not met, identify the strong reasons relied upon, supported by proportionate and transparent evidence.

6. Review the relationship between planned housing and employment growth, particularly where new employment allocations are proposed in or adjoining rural settlements.

7. Reassess suitable promoted village sites as part of a coherent alternative portfolio, taking account of their cumulative contribution to delivery, housing choice, affordable housing, SME participation and rural vitality.

8. Introduce additional flexibility into the housing trajectory through a geographically and commercially diverse range of allocations with different lead-in periods, delivery models and infrastructure requirements.

9. Consider HELAA site 40323 alongside other suitable promoted sites as an example of land which may contribute to the necessary diversification of supply, subject to appropriate site-specific assessment and mitigation.

The principle of directing substantial growth towards Cambridge, the edge of Cambridge and appropriately located strategic growth areas is broadly supported. Those locations can make an important contribution towards meeting the development needs of Greater Cambridge. The soundness concern is therefore not founded upon an objection to strategic growth in principle. Rather, it arises from the degree to which the Plan concentrates future housing delivery within a relatively narrow range of large and complex locations, while assigning only a limited and largely residual role to small and medium-sized sites and sustainable rural settlements, an example being Over, which is identified as a Group Village within the settlement hierarchy. It is noted that whilst this representation focuses on the overall spatial strategy, our client has a direct interest in the Land north of Willingham Road, Over. As such our comments also focus on small/medium scale development sites.

With regard to the spatial strategy, it also risks overlooking the needs of communities towards the periphery of the Plan area. Not all residents will work in or travel to Cambridge, and sustainable settlements such as Over have an important role in meeting wider housing needs and supporting a more balanced distribution of growth across Greater Cambridge. The Council’s spatial search sequence prioritises opportunities within Cambridge, followed by the edge of Cambridge, new settlements and then better-served villages. Although such a sequence may represent a legitimate starting point for assessing broad spatial options, it does not itself demonstrate that the distribution ultimately selected is the most appropriate strategy. A sequential search process should not become a rigid hierarchy under which otherwise sustainable opportunities are discounted merely because sufficient theoretical capacity has first been identified within locations appearing earlier in the sequence. The strategy offers no flexibility for changing circumstances.

The relevant question for soundness is not simply whether the preferred strategic locations are capable of accommodating development. It is whether the overall distribution represents an appropriate, balanced and deliverable strategy when compared with the reasonable alternatives. That requires consideration of the cumulative benefits of a more diverse portfolio, including the contribution that smaller and medium-sized sites in sustainable settlements could make to early delivery, market choice, affordable housing provision, rural vitality and the resilience of the housing trajectory.

The Plan has not adequately demonstrated why these benefits have been afforded comparatively limited weight. Nor has it demonstrated why a strategy incorporating a greater proportion of suitably located small and medium-sized allocations would not represent a more balanced and effective approach.


THE SPATIAL STRATEGY IS NOT JUSTIFIED

To be justified, the Plan must represent an appropriate strategy, taking reasonable alternatives into account and being based upon proportionate evidence. The Council has identified and assessed a range of development opportunities, but the existence of an extensive evidence base does not, by itself, establish that the strategy selected is the most appropriate one.

The Plan’s approach appears to proceed from the broad assumption that the concentration of development at Cambridge, its edge and strategic growth locations is inherently preferable to distributing a modestly greater proportion of growth to sustainable villages. That proposition requires more careful examination. Sustainability is not determined solely by settlement size or by a settlement’s position within a strategic search sequence. It also depends upon the relationship of development to existing services, employment, public transport, community infrastructure and the capacity of individual places to accommodate proportionate growth.

The Plan should therefore distinguish between rural locations that are poorly served, physically constrained or inadequately related to existing settlements and those where modest growth could be accommodated sustainably. A strategy which treats village development primarily as a residual element can risk overlooking meaningful differences between settlements and between individual development opportunities. It also fails to recognise the benefits that growth can have to the viability of local services and facilities. This is particularly relevant in the context of demographic change within rural Cambridgeshire. Census 2021 analysis undertaken by Cambridgeshire & Peterborough Combined Authority (Research Team, Business Intelligence, 2022) identifies substantially greater growth in the population aged 65 and over across the County's rural districts than in younger and working-age groups. A strategy which places excessive restraint on otherwise sustainable village growth therefore risks reinforcing, rather than responding to, an increasingly unbalanced demographic profile.

The proposed restrictions applicable to Group Villages illustrate the concern. Policy S/SH generally limits residential development within Group Villages to an indicative maximum of eight dwellings, with schemes of up to around 15 dwellings only contemplated exceptionally where they would make the best use of a single brownfield site. In practice, this provides very limited scope for planned and proportionate growth at otherwise sustainable villages, including on suitable land immediately adjoining existing settlement boundaries.

This is not a new approach. It substantially continues the restrictive framework established by Policy S/10 of the adopted South Cambridgeshire Local Plan 2018, which permits residential development of up to eight dwellings within Group Village development frameworks. The proposed strategy therefore carries forward a long-established constraint on the scale and location of development within Group Villages, rather than providing greater flexibility to accommodate proportionate growth where suitable and deliverable opportunities arise.

Given that this approach has already operated through successive plan-making, it is reasonable to question whether simply carrying forward broadly the same thresholds provides a sufficiently responsive basis for meeting housing needs over a further plan period, particularly where opportunities within established development frameworks are necessarily finite.

The strategy therefore risks applying broad restraint without sufficiently differentiating between unsuitable countryside development and well-related village-edge opportunities. A more proportionate approach would identify the better-performing rural settlements and then select the most sustainable and deliverable opportunities associated with them. This would not require unrestricted rural growth, nor would it undermine the principal focus upon Cambridge and the strategic locations. It would instead introduce greater balance into the selected strategy.

The Council should also demonstrate that reasonable alternatives involving a larger contribution from small and medium-sized sites and Group Villages were considered on a genuinely comparable basis. It is insufficient merely to record that promoted sites were assessed. The soundness evidence should explain whether a coherent alternative distribution incorporating a greater number of such sites was tested, how its sustainability and delivery implications compared with the preferred strategy, and why it was rejected.

Without that comparative assessment, it is not clear that the Plan’s limited role for sustainable villages results from a balanced evaluation of alternatives, rather than from the prior application of a search sequence which inherently favours large strategic locations.


INSUFFICIENT PROVISION FOR SMALL AND MEDIUM-SIZED SITES

A central weakness in the strategy is the limited planned role assigned to small and medium-sized housing sites.

The Plan’s evidence refers to completions, commitments, proposed allocations and anticipated windfall development when assessing the contribution of smaller sites. However, these components are not interchangeable. Historic completions concern development already delivered. Commitments arise from decisions made before the adoption of the new Plan. Windfalls are, by definition, not specifically identified; they are not confined to small and medium-sized sites and can also be very large in scale. Windfall provision cannot, therefore, be relied upon to justify the Plan’s approach to small and medium-sized sites. Together, these sources may contribute towards housing supply, but they do not remove the need for the Plan itself to allocate an appropriately diverse portfolio of new sites.

A district-wide numerical calculation also does not demonstrate that the spatial distribution of small and medium-sized sites is appropriate. It cannot establish whether those sites are spread across a suitable range of settlements, whether they will support identified rural communities, or whether they will provide a reliable source of housing throughout the Plan period.

The strategic purpose of allocating smaller and medium-sized sites extends beyond meeting an aggregate numerical target. Such allocations can:
• provide an earlier contribution to housing delivery;
• broaden the range of developers and delivery models;
• create opportunities suitable for SME housebuilders;
• increase market choice and competition;
• support delivery across different housing market areas;
• provide additional opportunities for affordable housing;
• sustain services and facilities in existing communities; and
• provide a complementary source of supply where strategic allocations experience delay.

These are benefits of the portfolio as a whole. The case for diversification does not depend upon proving that any particular strategic allocation will fail. A sound plan should anticipate the possibility that some large sites will progress more slowly than expected and should establish sufficient flexibility to respond to that risk.

As detailed within the Consultation Statement, Appendix 6: Response to Representations, “Strategic and smaller scale development” at pp.112–115, representations raised concern that the strategy places an over-reliance on a few large strategic sites, that the Plan should include a greater mix of smaller and medium-sized sites, and that the development strategy does not adequately provide for rural and village growth. The representations specifically identify the benefits of smaller sites for housing delivery, five-year housing land supply, SME housebuilders, housing choice and meeting local housing needs. Nevertheless, no additional allocations were introduced in the Rest of the Rural Area at the Regulation 19 stage.


THE STRATEGY IS NOT EFFECTIVE

The effectiveness of the Plan depends not only upon the total capacity identified but also upon the timing, complexity and certainty of delivery.

A substantial proportion of the strategy relies upon large development locations and infrastructure programmes requiring coordination between landowners, developers, infrastructure providers, statutory bodies and public authorities. The Council’s own material acknowledges dependencies relating to transport schemes, public transport corridors, water supply, wastewater infrastructure and other utilities. It also identifies related risks to housing delivery and the maintenance of a five-year housing land supply.

The existence of these dependencies does not necessarily mean that the strategic allocations are undeliverable. It does, however, make flexibility and contingency an essential component of the strategy. A plan which concentrates delivery within a relatively small number of large allocations will be more exposed to changes in infrastructure programming, statutory approvals, funding, viability, land assembly and market conditions.

The Council should therefore demonstrate that the housing trajectory has been subject to appropriate and robust testing. In particular, the evidence should explain how the Plan would respond if one or more major allocations were delayed, if infrastructure were delivered later than assumed, with particular regard to adequate water supplies, or if build-out rates were lower than anticipated. The availability of a theoretical housing buffer would not necessarily resolve these concerns if the buffer itself is concentrated within the same categories of complex or infrastructure-dependent development.

A more diverse portfolio of allocated sites would materially improve effectiveness. Small and medium-sized developments will not replace strategic locations and cannot individually deliver the same scale of infrastructure or housing. Their value lies in their ability to provide multiple, complementary sources of supply with differing delivery characteristics. Collectively, they can reduce the consequences of delay at any one location and increase the likelihood that housing will be delivered at the time envisaged.

The Plan should therefore allocate a meaningful range of smaller and medium-sized sites capable of contributing during the early and middle parts of the Plan period. The Plan should therefore allocate a meaningful range of small and medium-sized sites capable of contributing during the early and middle parts of the Plan period, as such sites can typically come forward within the first five years. Such sites can provide a flexible and responsive source of housing supply, particularly at the point when maintaining a robust five-year housing land supply and confidence in the overall housing trajectory is most important. Their allocation would supplement, rather than displace, the strategic sites, broadening the sources of housing delivery and providing greater resilience should delivery on larger sites be delayed or fall below anticipated rates. This would provide greater confidence that the housing requirement can be met consistently throughout the Plan period.


THE STRATEGY IS NOT CONSISTENT WITH NATIONAL POLICY

Chapter 6 (Delivering a sufficient supply of homes) of the 2026 National Planning Policy Framework (NPPF) requires local plans to secure an appropriate supply and mix of sites and to maintain a diverse portfolio of development opportunities.

Paragraph 73 of the NPPF states that “small and medium sized sites can make an important contribution to meeting the housing requirement of an area.” Paragraph 73(a) requires land to be allocated to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless strong reasons demonstrate that those targets cannot be achieved.

The provision in the NPPF establishes an express expectation that small and medium-sized sites should form a meaningful part of the planned housing strategy. If the Council does not propose to meet either target, it must identify clear and evidenced reasons explaining why achievement is not reasonably possible.

A general preference for larger strategic growth locations would not, without further evidence, amount to a strong reason. Nor would a calculation which combines past completions, existing commitments and unidentified future windfalls necessarily demonstrate that the Plan’s allocation strategy is consistent with the intended purpose of the national policy. The relevant requirement concerns the allocation of land and therefore seeks a planned, identifiable and deliverable contribution from sites within the specified size categories.

The relevant question is therefore whether the Council has robustly tested whether the targets could reasonably be achieved through the site assessment and spatial strategy process. If suitable opportunities exist but have not been allocated because growth has instead been concentrated within larger strategic locations, that is a consequence of the chosen strategy rather than, in itself, a strong reason for departing from national policy. The preferred spatial strategy should not effectively become the justification for its own departure from the national policy expectation.

The Council should accordingly identify:
1. the amount of the housing requirement proposed to be accommodated on allocated sites of no more than one hectare;
2. the amount of the housing requirement proposed to be accommodated on small and medium-sized sites;
3. the spatial distribution of those allocations;
4. the anticipated phasing of their delivery;
5. the contribution they make to rural communities and SME delivery; and
6. any strong reasons relied upon where the relevant targets are not achieved.

This information should be transparent within the Plan and its supporting evidence. It should not be necessary to aggregate unrelated categories of supply to determine whether the underlying policy objective has been satisfied.

National policy also supports the allocation of sites which sustain and enhance rural communities and enable villages to grow and thrive, particularly where development would support local services. The Plan’s tightly constrained approach to village growth does not give sufficient practical effect to that objective.

Windfall development, rural exception sites and neighbourhood plans cannot be treated as complete substitutes for strategic allocations. Windfalls provide limited certainty over location, timing and scale and are a finite resource, particularly in areas of high demand. Rural exception sites address a particular form of housing need and are not equivalent to general housing allocations. Neighbourhood planning is voluntary and cannot be relied upon to remedy a deficiency in the strategic distribution established through the Local Plan.

The Local Plan itself must therefore establish a positive framework for proportionate rural growth.


RURAL VITALITY AND THE SETTLEMENT HIERARCHY

The settlement hierarchy should provide a basis for directing development to locations with an appropriate level of services, accessibility and community infrastructure. It should not operate as an inflexible limit which prevents sustainable opportunities from being considered on their individual merits.

Many rural settlements perform several functions simultaneously. They provide homes, employment, schools, shops, community facilities and public transport connections, while also supporting a wider rural hinterland. The long-term vitality of such settlements may depend upon a proportionate degree of population and housing growth.

Restricting planned development too severely can itself have sustainability consequences. It may reduce opportunities to meet locally arising housing needs, constrain the provision of affordable housing and limit the customer base available to support local services. The assessment of sustainability should therefore consider both the impacts of additional development and the consequences of an absence of planned growth.

The Plan should identify those villages which are capable of accommodating a proportionate level of development, taking account of:
• the availability and accessibility of services and facilities;
• diverse and balanced community needs;
• opportunities for walking, cycling and public transport;
• the existence of local employment;
• the physical relationship between promoted land and the settlement;
• landscape and settlement character;
• environmental and infrastructure constraints;
• the ability to secure mitigation; and
• the availability and achievability of individual sites.

This would allow growth to be directed selectively towards the most suitable opportunities rather than applying a broad presumption against village-edge allocations.


RELATIONSHIP BETWEEN HOMES AND EMPLOYMENT

The distribution of housing should also be considered alongside the Plan’s employment strategy.
Where the Plan supports new or expanded employment opportunities in rural settlements, it should consider whether an appropriate level of additional housing is needed to maintain a coherent relationship between homes and jobs. This does not require housing and employment growth to be matched arithmetically. It does require the spatial strategy to avoid an approach in which economic development is supported in rural locations while the occupation and growth of those communities are tightly restricted.

Over illustrates this wider point. The Plan proposes an extension to the Norman Way industrial estate, as detailed within Policy S/RRA/NW. The allocation seeks to provide approximately 6,100m2 of employment floorspace, while offering no comparable planned housing opportunity within the village. The example indicates that the Council considers the settlement capable of accommodating planned economic growth, but the Plan does not clearly explain why a proportionate housing allocation would be inconsistent with the same spatial objectives. A similar issue arises with the proposed allocations at the A14 Swavesey Services under Policies S/RRA/SCS and S/RRA/BBP, where substantial employment growth is proposed with limited corresponding housing provision. This again risks an imbalance between jobs and homes and strengthens the case for additional housing opportunities in nearby rural settlements.

This is not advanced as a site-specific argument applicable only to Over. It illustrates a broader need for the Plan to consider the relationship between planned employment, housing, local services and travel patterns across the rural area.


EVIDENCE OF REASONABLE ALTERNATIVES

The Council’s land availability assessment should inform, but not predetermine, the allocation process. Where sites are found to be available and achievable and are not subject to overriding constraints, they should be considered as part of reasonable alternative spatial strategies.

An ‘Amber’ assessment should not automatically be treated as equivalent to unsuitability. It may identify a need for further evidence, a reduced capacity, mitigation or site-specific policy criteria. Where those matters are capable of resolution, the site may remain a credible allocation option.

Land north of Willingham Road, Over, identified as HELAA site 40323, provides one example, as assessed within the Greater Cambridge HELAA (2021), Appendix 4. The assessment identifies a 1.94-hectare site adjoining a Group Village, with ‘Green’ availability and achievability assessments and anticipated delivery within the first five years. Its overall suitability is assessed as ‘Amber’, reflecting landscape, ecology and highway matters requiring further assessment. These matters are not identified as fundamental constraints to development and are capable of being addressed through appropriate site-specific assessment, mitigation and scheme design, including sensitive landscape treatment, ecological protection and enhancement measures, and suitable access and highway arrangements.

The purpose of referring to this site is not to make the wider strategic objection dependent upon its allocation. Rather, it demonstrates that promoted opportunities exist within the size category supported by national policy and that some could contribute to a more diverse, geographically balanced and resilient housing supply. The Council should reassess these opportunities collectively as part of a reasonable alternative involving a greater planned contribution from small and medium-sized developments and sustainable villages.


OVERALL SOUNDNESS CONCLUSION

The Proposed Submission Plan has not demonstrated that its highly concentrated distribution of growth represents the most appropriate strategy when compared with a more balanced alternative.

The strategy is not justified because the evidence does not adequately demonstrate why sustainable villages and small and medium-sized sites should play such a limited role, or why an alternative distribution incorporating a greater number of those sites was rejected. Where sites have been promoted and assessed as capable of contributing, they should be collectively tested as an alternative portfolio. It is insufficient to reject them individually without evaluating the cumulative effect of a more distributed strategy.

It is not effective because the concentration of housing delivery within large and complex locations exposes the trajectory to common infrastructure, phasing, viability and market risks without providing a sufficiently diverse supply of complementary allocations.

It is not consistent with national policy because it does not give sufficient practical effect to the requirement to allocate a meaningful proportion of housing on small and medium-sized sites or to support rural communities by enabling suitable villages to grow and thrive.

These concerns do not require the abandonment or substantial reduction of the Plan’s strategic locations. They require the strategy to be broadened so that those locations are complemented by an appropriate selection of deliverable small and medium-sized allocations distributed across sustainable settlements.