Greater Cambridge Local Plan: Proposed Submission

The Strategic Enhancement Area as shown in Figure 66 should be reduced to be incorporated fully within the Site Allocation and land under the control of the developer(s) for CBN rather than extending beyond the area which has been allocated. Instead, a suitable masterplan should be required to fit within the Site Allocation which takes into account the need for mitigation of any effects to the landscape character across land that is available to support the allocation.
Additionally, Criterion 15 and 37(d)(i) which require delivery of an extension of the Cambourne to Cambridge transport corridor should be removed as the land owned by the Varrier Jones Foundation is not available for this use.

Varrier Jones Foundation object to Policy S/CBN: Cambourne North. The wider Cambourne North Strategic Enhancement Area (S/SEA/CBN) Policy Area extends excessively far west so as to directly abut the village of Papworth Everard, including land in ownership by the Varrier Jones Foundation. Policy S/CBN describes this area as required to provide ‘sufficient physical and visual separation between the development and neighbouring settlement and maintain a soft, green landscape’. However, at Paragraph 14c it is noted that no detailed evidence has been prepared to justify this landscape buffer and instead these assessments will be undertaken in the future to inform the masterplan process. It is therefore considered that the allocation of the landscape buffer cannot be considered to be ‘justified’ or ‘based on proportionate evidence’ as required by the tests of soundness outlined in the NPPF (2024) at Paragraph 36. It is land not necessary to achieve a deliverable allocation. The Varrier Jones Foundation has not been approached by any party about the inclusion of the land or any change to it to fulfil any policy requirement for S/CBN.
Furthermore, the allocation of this buffer unfairly prejudices potential future development of parcels to the east of Papworth Everard. Varrier Jones Foundation have raised concern about the overreliance of the Plan on strategic sites, leaving a lack of housing supply in the first half of the plan period as outlined in the Bidwells Note on Housing Need and Supply Matters (Bidwells, 2026). As such, restricting potential sustainable development of small and medium sites at Papworth Everard directly adjacent to the existing Business Park in preference for some distant land designation from Cambourne North which heavily relies on forthcoming infrastructure along the Cambridge-Cambourne transport corridor is contradictory to the purposes of the Local Plan to meet the district’s housing need in sustainable locations.
Criterions 15 and Criterion 37(d)(i) includes for “an extension of the Cambourne to Cambridge public transport corridor into the site and beyond to Papworth Everard”. The location of this corridor is outlined in Figure 66 of the Local Plan: Indicative Spatial Framework for Cambourne North (also enclosed with this representation for ease). Varrier Jones Foundation support the Cambourne to Cambridge public transport corridor, but as the relevant landowners for this extension to Papworth Everard would like to note that this land is not available to support the Cambourne North allocation; no approach has been received to Varrier Jones Foundation by the Planning Authority or the developer(s) to explore the land requirements to deliver the route as indicated on the Indicative Spatial Framework.

In order to overcome the issues highlighted in this representation and the enclosed Note on Housing Need and Supply matters and progress a sound Local Plan, it will be necessary to undertake the following additional work and revise the proposed housing requirement accordingly:
• Increase the housing requirement to reflect as a minimum the minimum local housing need of the standard method for 48,090 homes.
• Prepare housing projections which align with the economic ambitions set out in the recently adopted Local Growth Plan, which the CPCA suggest will necessitate a requirement of at least 59,409 homes but potentially substantially more.
• Consider whether it would be sustainable to deliver a greater number of homes to better respond to the acute need for affordable housing.
In light of the available evidence, this will necessitate a requirement of at least 59,409 homes over the plan period to support the local and national economy, rather than the proposed insufficient housing requirement of 48,069 homes which falls short of meeting even the minimum local housing need and pays no regard to the level of housing necessary to support the local and national economy.
To meet this additional need requires the allocation of medium sites which can be delivered in the first half of the plan period. This should include the allocation of some or all of Land to West of Papworth Everard, known as Parcels A and B (HELAA 2026 site ID 40428) which represents an available and deliverable site for development of up to 452 dwellings. The large parcel of land available enables careful Masterplanning to ensure the best possible delivery on Site and a smaller or larger area could be allocated to meet the shortfall in housing numbers whilst bringing vitality through development to the rural area.
As a registered charity, Varrier Jones Foundation (VJF) has a deep and intertwined legacy with the history of Papworth Everard (Papworth). A unique and large custodian in the village, VJF is able to approach development collaboratively and holistically, with the capacity to provide facilities and beneficial development for the community in targeted locations throughout the village. Therefore a master plan strategy spanning Parcels A and B represents a landscape led development which provides a sensitive and contextually appropriate addition to Papworth, responding to the site’s sensitive heritage and landscape constraints.
Site A is considered suitable for a landscape-led residential development of between 302-452 dwellings, subject to stakeholder engagement and statutory consultees involvement to shape the proposal and what scale of benefits are preferred. The site is located along the western side of the village and is enclosed by the A1198 bypass which acts as a defensible boundary and forms an enclosed parcel of land that can now have a planned and designed purpose put to it. The site would include affordable housing, landscaping, and a variety of open space. Cycle and pedestrian links would be retained and improved as part of the proposed development
Site B is the north western parcel and is proposed as land with potential for a primary school expansion or for community use, representing a demonstrable benefit to existing and future residents of Papworth Everard and an opportunity to enhance the vitality of this rural community.

The Varrier Jones Foundation object to Policy S/JH. The policy is unsound as it is not positively prepared, not justified, not effective and inconsistent with national policy.
These representations are supported by the enclosed Note on Housing Need and Supply Matters. This concludes that the proposed housing requirement of Policy S/JH is unsound because:
i. It is not positively prepared as it does not meet even the minimum local housing need of the standard method, let alone reflect the economic ambitions of the government as expressed through the Local Growth Plan or respond sufficiently to the acute need for affordable housing.
ii. It is not justified as it does not provide any justification for a housing requirement below the minimum local housing need of the standard method, it does not even consider providing for a level of housing which aligns with local and national economic growth ambitions, and it has not considered whether a greater number of homes should be provided to better respond to affordable housing needs.
iii. It will not be effective, as it will not meet housing needs, support local and national economic ambitions or deliver as much affordable housing as could sustainably be achieved.
iv. It is inconsistent with national policy as it does not meet the minimum local housing need of the standard method contrary to the requirements of paragraph 62 of the NPPF, and it does not support the planned economic growth contrary to the PPG (2a-040) and paragraph 86d of the NPPF, and it is not informed by a consideration of a greater housing requirement to better meet affordable housing needs contrary to the requirements of the PPG (2a-024).
In terms of the policy context, paragraph 69 of the NPPF (2024) notes an Authority may need to plan for greater housing growth above their identified need to reflect growth ambitions linked to economic development or infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024) confirms that planning policies should seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment. The draft Plan does not do this. This message is translated into HO2(b) of the NPPF (2026) and it is clear that housing requirements within Local Plans should be set higher than the figure identified within a housing needs assessment where appropriate. It is confirmed that such circumstances include where a higher housing requirement is necessary to reflect growth ambitions linked to economic investment or infrastructure investment. Whilst the GCLP will be assessed against the NPPF (2024), it is clear the direction being established by central government is one of growth, with a particular focus on Cambridge and the surrounding region.
This need for growth is evidenced by national, regional and authority level investment in infrastructure including the new Cambridge South Railway Station providing direct connectivity between Cambridge Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context, the commitment to East West Rail establishes the area as one benefiting from continued investment in major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by the Greater Cambridge Development Corporation (GCDC) set to deliver infrastructure first growth. We contend in order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for growth must be realised now within the emerging Local Plan.
The approach of the LPA may be that the GCDC will deliver the growth over-and-above the minimum provision in the Draft Local Plan, but; the GCDC is yet to receive plan-making powers; it will prepare a Plan after the adoption of the Draft GCLP; it will need to undertake formal consultation and examination in public in the normal way to lead to a formally adopted “successor” Plan. Such a successor Plan will be many years away, while the growth ambition is now. The GCLP needs to address growth now and not rely on a possible GCDC Plan.
The proposed housing requirement of just 48,069 homes in the GCLP, which reflects the minimum identified by the standard method, will clearly act to constrain the economic ambitions of the Local Growth Plan contrary to paragraph 86d of the NPPF. The Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026) provides further support for this position. Using the latest 2026 housing stock and affordability inputs, it identifies a Standard Method minimum of 2,290 homes per annum, or 48,090 homes over the Plan period, and records the CPCA’s position that at least 59,409 homes should be planned for to support economic growth. These findings reinforce the Varrier Jones Foundation’s existing case for a more ambitious housing requirement.
Furthermore, The Housing Delivery Addendum 2026 Update uses the Liverpool Approach to calculating housing need and seeks to argue that the Liverpool approach is appropriate notwithstanding the fact that it concludes that a five-year land supply will be able to be demonstrated using the standard Sedgefield approach. This is clearly inconsistent with the recommendations of national guidance (PPG 68-031). It is also not positively prepared as it serves to introduce a policy to reduce the requirement throughout the plan period rather than identifying a sufficient supply of deliverable sites to meet housing needs and support the government’s objectives. The Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026) outlines that the Sedgefield approach should be used as per government recommendation, however the report goes on to show that the authority can only demonstrate a 4.41 year supply under the Liverpool, or 4.06 years with Sedgefield anyway, and as such it is a moot point.
The fact that the GCLP is not planning for the level of growth necessary to support the economic ambitions of the Local Growth Plan, which align with the economic objectives of the government is underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the basis of standard economic forecasts which are inevitably trend-based and so do not account for economic potential of the area as is necessary to align with local and national economic ambitions. The EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the ‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could be achieved with step change in investment.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater job growth in the region will generate a derived demand for housing, creating an interdependency between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario. Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is acknowledged the Standard Method does not take into account the specific growth agenda and focus on Cambridge as an area of ‘supercharged growth’.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm Cambridge’s position as an area capable of supporting and delivering high growth. Within this context Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.
We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in stating the fact that average household sizes are now larger, leading to an increase in people of working age and more in-commuting which reduces the number of local people required to fill jobs created. We raise concern this is an unsustainable approach to development strategy and reflects a local housing market where many young people are unable to move out of their family homes and move closer to or within Cambridge where jobs are located at key existing and development employment centres such as CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to address the affordability of housing within Greater Cambridge by planning for increased growth and supply to reflect growing demand rather than embed the issue of increasing household size.
In doing so and making provision for increased housing stock in Greater Cambridge in sustainable locations would ensure the Local Plan promotes more suitable patterns of travel as required by paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys required for employment.

Policy S/DS should be modified to provide a more balanced and diversified distribution of housing growth, including a greater role for small and medium-sized sites capable of contributing in early parts of the Plan period.
Additional sustainable and deliverable sites identified through the Call for Sites process should be allocated in order to reduce delivery risk and reliance upon unidentified windfall development. This should include the allocation of some or all of Land to West of Papworth Everard, known as Parcels A and B (HELAA 2026 site ID 40428) which represents an available and deliverable site for development of up to 452 dwellings. The large parcel of land available enables careful Masterplanning to ensure the best possible delivery on Site and a smaller or larger area could be allocated to meet the shortfall in housing numbers whilst bringing vitality through development to the rural area.
As a registered charity, Varrier Jones Foundation (VJF) has a deep and intertwined legacy with the history of Papworth Everard (Papworth). A unique and large custodian in the village, VJF is able to approach development collaboratively and holistically, with the capacity to provide facilities and beneficial development for the community in targeted locations throughout the village. Therefore a master plan strategy spanning Parcels A and B represents a landscape led development which provides a sensitive and contextually appropriate addition to Papworth, responding to the site’s sensitive heritage and landscape constraints.
Site A is considered suitable for a landscape-led residential development of between 302-452 dwellings, subject to stakeholder engagement and statutory consultees involvement to shape the proposal and what scale of benefits are preferred. The site is located along the western side of the village and is enclosed by the A1198 bypass which acts as a defensible boundary and forms an enclosed parcel of land that can now have a planned and designed purpose put to it. The site would include affordable housing, landscaping, and a variety of open space. Cycle and pedestrian links would be retained and improved as part of the proposed development
Site B is the north western parcel and is proposed as land with potential for a primary school expansion or for community use, representing a demonstrable benefit to existing and future residents of Papworth Everard and an opportunity to enhance the vitality of this rural community.

The Development Strategy continues to place substantial reliance upon a relatively small number of large strategic sites to accommodate housing growth. Varrier Jones Foundation does not object to strategic-scale development forming an important component of the Local Plan. The objection concerns the degree of reliance placed upon large and infrastructure-dependent sites without a sufficiently diverse portfolio of smaller and medium-sized sites capable of contributing throughout the Plan period.
This concern was raised by various consultees at Regulation 18 and was supported by the Technical Note on Delivery of Strategic Housing Sites within Greater Cambridge (Bidwells, January 2026). The Technical Note reviewed nine strategic housing sites, which found that of the seven which had delivered housing, there was an average delay of approximately 4.9 years between the Councils first anticipated housing completions and actual first delivery. This concern is further reinforced by Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026), which tests the latest trajectory and identifies that Northstowe, Cambridge East (Airport) and Waterbeach New Town are assumed to achieve delivery rates above those sustained on the strategic sites considered in the Start to Finish evidence. Even assuming delivery equivalent to the strongest comparator, the report identifies 3,581 fewer homes from these three sites over the Plan period than assumed by the Councils.
The Proposed Submission Plan does not remove this delivery concern. In particular, Cambourne North is proposed for approximately 13,000 homes, of which 2,550 homes are anticipated within the Plan period. Development is identified as commencing from 2034, subject to the necessary water infrastructure being available, and the Plan identifies the East West Rail station and Cambourne-to-Cambridge high-quality public transport corridor as central to its accessibility.
Similarly, Grange Farm is proposed for approximately 4,500 homes, with 2,550 homes by 2045, again subject to necessary water infrastructure being available. The policy also states that the new settlement will play a critical role in extending the Cambridge South East Transport (CSET) scheme.
The Plan identifies a total housing supply of 52,032 homes against the requirement for 48,069 homes, providing 8.2% headroom. However, aggregate headroom does not address the timing or distribution of delivery. Greater Cambridge Housing Need and Supply Matters (Bidwells, 2026) further tests the claimed supply and, after applying its adjustments for first-five-year windfall, sites not expected to deliver and strategic-site delivery rates, identifies a plan-period supply of at most 46,687 homes.
The Plan expressly acknowledges that sustained annual completions at or above the housing requirement are not anticipated until the second half of the Plan period, owing to the chosen development strategy and water and transport infrastructure constraints. It relies upon this position to justify use of the Liverpool methodology for calculating five-year housing land supply.
Appendix D consequently calculates a 5.47-year housing land supply for 2028–2033 using the Liverpool methodology and a 5% buffer. Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026) tests the components of that supply and reaches a materially different conclusion. It considers that the 1,562-home windfall allowance in 2028–2033 should not form part of the specific deliverable supply and makes a further adjustment of at least 1,068 homes at Northstowe and Waterbeach New Town. On that basis, it identifies a deliverable supply of at most 11,005 homes, equivalent to 4.41 years using Liverpool and 4.06 years using Sedgefield. This reinforces the importance of identifying additional deliverable sites capable of contributing while the larger strategic allocations and their supporting infrastructure are progressed.
A more diversified portfolio of sustainable and deliverable sites would therefore reduce delivery risk and provide a more continuous supply of housing throughout the Plan period. Additional sustainable and deliverable sites identified through the Call for Sites process should be allocated in order to reduce delivery risk and reliance upon unidentified windfall development. This should include the allocation of some or all of Land to West of Papworth Everard, known as Parcels A and B (HELAA 2026 site ID 40428) which represents an available and deliverable site for development of up to 452 dwellings. The large parcel of land available enables careful Masterplanning to ensure the best possible delivery on Site and a smaller or larger area could be allocated to meet the shortfall in housing numbers whilst bringing vitality through development to the rural area.
As a registered charity, Varrier Jones Foundation (VJF) has a deep and intertwined legacy with the history of Papworth Everard (Papworth). A unique and large custodian in the village, VJF is able to approach development collaboratively and holistically, with the capacity to provide facilities and beneficial development for the community in targeted locations throughout the village. Therefore a master plan strategy spanning Parcels A and B represents a landscape led development which provides a sensitive and contextually appropriate addition to Papworth, responding to the site’s sensitive heritage and landscape constraints.
Site A is considered suitable for a landscape-led residential development of between 302-452 dwellings, subject to stakeholder engagement and statutory consultees involvement to shape the proposal and what scale of benefits are preferred. The site is located along the western side of the village and is enclosed by the A1198 bypass which acts as a defensible boundary and forms an enclosed parcel of land that can now have a planned and designed purpose put to it. The site would include affordable housing, landscaping, and a variety of open space. Cycle and pedestrian links would be retained and improved as part of the proposed development
Site B is the north western parcel and is proposed as land with potential for a primary school expansion or for community use, representing a demonstrable benefit to existing and future residents of Papworth Everard and an opportunity to enhance the vitality of this rural community.

In order to be found sound the GCLP will need to identify additional allocations to deliver a substantial number of additional homes as outlined in The Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026) report and summarised in objections to Policy S/JH and S/DS.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is Land to the west of Papworth Everard known as Parcels A and B (HELAA 2026 site ID 40428). The site is considered to represent a sustainable location for development which will help to meet the housing needs of Greater Cambridge in Local Plan period. With the right design, including a suitable layout and design concept, the proposed development on the site could be accommodated without having a significant impact on the surrounding landscape setting. which represents an available and deliverable site for development of up to 655 dwellings. The large parcel of land available enables careful Masterplanning to ensure the best possible delivery on Site and a smaller or larger area could be allocated to meet the shortfall in housing numbers whilst bringing vitality through development to the rural area. The Site represents logical infill between the village of Papworth Everard to the east and the B1040 and A1198 to the west and has already been subject to a Masterplanning exercise which has been shared with the LPA.

The proposed development strategy’s lack of commitment to delivering growth in sustainable settlements in the rural area risks exacerbating the affordability crisis in Greater Cambridge, likely pushing younger people out of their local communities and support networks. Reliance on strategic settlements outside of the Green Belt (and hence further away from Cambridge) is also likely to increase car dependency.
The proposed development strategy is focused on a few strategic sites for new housing development, particularly in the Rural Area. There are very few small and medium size housing sites allocated in the Rural Area; which the NPPF (2026) recognises the important contribution such sites can make to an Authority’s housing supply.  
The proposed approach would form a constraint on the sustainable development of many settlements and their communities. In particular, the lack of housing allocations in the villages fails to support the delivery of homes to meet the local housing needs of the next generation during the plan period. Instead of being able to live locally, this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere – often away from their existing family, community and support network. This leads to an increased need for travel within Greater Cambridge, often via private cars rather than public transport. It also results in population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the new settlements have predominantly young populations and significant pressure on services.
To ensure the continued vitality of historic settlements across Greater Cambridge in the rural area an appropriate degree of housing and employment growth is required to ensure economic footfall is placed into such settlements and their respective highstreets, services and facilities.
Furthermore, at present the strategy proposes to deliver the majority of development at new towns and settlements within the Authority (Northstowe, Cambourne, Waterbeach and Grange Farm). Whilst the approach to deliver housing at scale is commended, the NPPF (2024) explicitly requires Authorities to enable a sufficient amount of land to come forward for residential development to meet the housing needs of the whole community taking into account need, size, type and tenure (NPPF paragraphs 61 – 63). To meet the needs of the whole Authority we contend a variety of land across the Authority needs to be identified for development. In allocating the majority of proposed housing at new settlements and new towns ignores the desire many may have within the Authority to live in the existing settlements and villages located across the rural area. This both reduces market competition and choice which is likely to have a detrimental impact on house prices and market availability.
A more balanced approach is required in respect to the Rural Area, including a wider range of housing sites being allocated – in terms of both site sizes and locations. This is necessary to ensure that the Local Plan supports sustainable communities and sustainable patterns of growth. In addition to providing housing to support new jobs in Cambridge and the key employment growth sectors, the development strategy should take account of the needs and vitality of existing villages and the wider rural economy and make planned provision for them. 
In many villages, there is a lack of brownfield land available within the ‘defined development extents’ to facilitate housing delivery in accordance with the approach set out in Draft Policy S/SH (Settlement hierarchy). Also, small windfall sites provide limited affordable housing to meet local needs. Hence, there should be specific land allocations for housing development in some of the rural villages, to promote genuinely sustainable growth and development – supporting the rural economy, promoting mixed and inclusive communities and ensuring the vitality and viability of local services. 
It is therefore proposed that further sites need to be allocated in the Rural Area in order to support vitality and viability of local services, as well as offer choice for young people within their existing support networks. This also serves to provide more small and medium sites in the first part of the plan period while infrastructure for strategic sites is delivered.
One such site is Land to West of Papworth Everard, known as Parcels A and B (HELAA 2026 site ID 40428) which represents an available and deliverable site for development of up to 452 dwellings. The large parcel of land available enables careful Masterplanning to ensure the best possible delivery on Site and a smaller or larger area could be allocated to meet the shortfall in housing numbers whilst bringing vitality through development to the rural area.
As a registered charity, Varrier Jones Foundation (VJF) has a deep and intertwined legacy with the history of Papworth Everard (Papworth). A unique and large custodian in the village, VJF is able to approach development collaboratively and holistically, with the capacity to provide facilities and beneficial development for the community in targeted locations throughout the village. Therefore a master plan strategy spanning Parcels A and B represents a landscape led development which provides a sensitive and contextually appropriate addition to Papworth, responding to the site’s sensitive heritage and landscape constraints.
Site A is considered suitable for a landscape-led residential development of between 302-452 dwellings, subject to stakeholder engagement and statutory consultees involvement to shape the proposal and what scale of benefits are preferred. The site is located along the western side of the village and is enclosed by the A1198 bypass which acts as a defensible boundary and forms an enclosed parcel of land that can now have a planned and designed purpose put to it. The site would include affordable housing, landscaping, and a variety of open space. Cycle and pedestrian links would be retained and improved as part of the proposed development
Site B is the north western parcel and is proposed as land with potential for a primary school expansion or for community use, representing a demonstrable benefit to existing and future residents of Papworth Everard and an opportunity to enhance the vitality of this rural community.

The policy should be strengthened to reflect the scale of growth ambitions for Greater Cambridge and the significant public investment being made in strategic infrastructure. The Local Plan should proactively support Cambridge’s role as a nationally important knowledge economy by increasing housing delivery across the plan period to ensure the workforce needed for future job growth can be accommodated.
The Plan should not rely on the future Greater Cambridge Development Corporation to deliver growth beyond the current allocations. While the GCDC has been established, it has yet to secure plan-making powers and any formally adopted 'successor' plan is likely to be many years away. Given the immediate growth ambitions for Greater Cambridge, the Local Plan must address these requirements now to provide certainty, support investment, and ensure growth now. As such, suitable employment sites should be allocated to support a diverse range of jobs by type and location. One such site is Land to the east of Stirling Way, Papworth Everard, known as Parcel C (HELAA 2026 site ID 40429). Please note that this Site has been incorrectly recorded as Land to the west of Stirling Way in the 2026 HELAA Sites Register, however as shown by the Site Plan in the HELAA and appended to this submission, the land is to the east of Stirling Way.
Furthermore, the reference to 73,300 additional jobs should be treated as a minimum target rather than expressed, or even inferred, as a cap on growth beyond this number. As currently drafted, there is a risk that the figure could be interpreted as limiting future employment growth opportunities. The policy should make clear that the target represents a minimum level of employment growth and should not act as a constraint to the delivery of additional jobs where sustainable economic opportunities arise through acceptable developments at that time.

The Varrier Jones Foundation object to draft policy S/JH. Paragraph 69 of the NPPF (2024) is clear that Authorities need to plan for higher levels of growth than the Standard Method requirement to reflect growth ambitions linked to economic development and infrastructure investment. The draft plan does not do this. Cambridge and the surrounding region is central to the government’s ambition to ‘supercharge’ growth. The draft plan does not reflect this ambition and will not meet the government’s expectations.
This is backed by national, regional and authority level investment in infrastructure including the new Cambridge South Train Station providing direct connectivity between CBC and London, the granting of the Cambourne to Cambridge bus way and progression of Cambridge South East Transport to inquiry later this year. In a national context the commitment to East West Rail establishes the area as one benefiting from continued investment in major transport infrastructure. Growth envisioned by government is set to be realised and delivered by the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in order to ensure the plan is found sound the unique nature of Cambridge and its projected capacity for growth must be realised within the emerging Local Plan.
We acknowledge Policy S/JH identifies a housing need for Greater Cambridge of 48,069 over the plan period, which equates to 2,289 dwellings per annum, consistent to the Standard Method output for the identified housing need of Greater Cambridge. Notwithstanding the Employment and Housing Needs Update (EHNU) (2026) adopts the preferred employment scenario which will generate 73,248 jobs over the plan period which aligns to generating a housing need of 48,069 dwellings across the plan period. The EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the ‘higher growth scenario’ dismissed. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Draft Local Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
However it is noted the EHNU notes that the higher scenario could be achieved with step change in investment. Such a step change now seems likely for the district, with the advent of the Greater Cambridge Development Corporation (backed by £400 million of central government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario. Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is acknowledged the Standard Method does not take into account the specific growth agenda and focus on Cambridge as an area of ‘supercharged growth’.
Further Greater Cambridge has benefited from recent and will benefit from future planned major infrastructure development which establishes Greater Cambridge as a place of regional and national importance where growth should be accommodated. The East-West Rail DCO is anticipated to be submitted in 2027 which will deliver a new station at Cambourne and run services through the newly opened Cambridge South Station alongside the other two train stations in Cambridge. Further Cambourne to Cambridge Busway has now received consent and is anticipated to be delivered shortly. Cambridge South East Transport (CSET) also is set to proceeded inquiry shortly further demonstrating the ongoing commitment to the delivery of major transport infrastructure in the region to support future growth.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm Cambridge’s position as an area capable of supporting and delivering high growth. Within this context Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’.
The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.  
For these reasons, the Local Plan should consider utilising more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.

In order to be found sound the GCLP will need to identify additional allocations to deliver a substantial uplift in employment space.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is Land to the east of Stirling Way, Papworth Everard, known as Parcel C (HELAA 2026 site ID 40429). The site could deliver up to 65,000m2 of employment floorspace and is considered to represent a sustainable location for development which will help to meet the employment needs of Greater Cambridge in Local Plan period. With the right design, including a suitable layout and design concept, the proposed development on the site could be accommodated without having a significant impact on the surrounding landscape setting.

Varrier Jones Foundation believe that the employment provision ambitions within the Local Plan should be strengthened to reflect the scale of growth ambitions for Greater Cambridge and the significant public investment being made in strategic infrastructure. The Local Plan should proactively support Cambridge’s role as a nationally important knowledge economy by increasing housing delivery across the plan period to ensure the workforce needed for future job growth can be accommodated
Employment areas should be situated in a variety of locations to ensure that patterns of commuting are sustainable and aligned with the needs of those in the district, for example where childcare needs are met by family members in the rest of the rural area, or where residents choose to locate further from the city in reflection of house prices in the city centre. As it has been established that more employment land must be allocated across the district, some must be directed to the Rural Area through the allocation of additional suitable sites.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is Land to the east of Stirling Way, Papworth Everard, known as Parcel C (HELAA 2026 site ID 40429), which could host up to 65,000m2 of employment floorspace, alongside delivery of a substantial amount of open space for new and existing residents and the opportunity to deliver biodiversity net gain of at least 20%. Please note that this Site has been incorrectly recorded as Land to the west of Stirling Way in the 2026 HELAA Sites Register, however as shown by the Site Plan in the HELAA and appended to this submission, the land is to the east of Stirling Way.
Site C is considered suitable for a landscape-led development which provides a sensitive and contextually appropriate commercial extension to Papworth with numerous benefits to the community and enhancements to local biodiversity. The site is located adjacent to the existing business park and with demand for growth at the Park there is an opportunity to bring forward an allocation to help meet this demand.
As a registered charity, VJF has a deep and intertwined legacy with the history of Papworth Everard. A unique and large custodian in the village, VJF is able to approach development collaboratively and holistically, with the capacity to provide facilities and beneficial development for the community throughout the village. VJF is committed to delivering a well-designed, high quality development that could form an extension to the existing business Park. The Site is capable of accommodating a landscape-led commercial development with access via Stirling Way for a range of potential employment uses or supporting facilities.

In light of the available evidence, this will necessitate a requirement of at least 59,409 homes over the plan period to support the local and national economy, rather than the proposed insufficient housing requirement of 48,069 homes which falls short of meeting even the minimum local housing need and pays no regard to the level of housing necessary to support the local and national economy.
To meet this additional need requires the allocation of medium sites which can be delivered in the first half of the plan period. This should include the allocation of some or all of Land to West of Papworth Everard, known as Parcels A and B (HELAA 2026 site ID 40428) which represents an available and deliverable site for development of up to 452 dwellings. The large parcel of land available enables careful Masterplanning to ensure the best possible delivery on Site and a smaller or larger area could be allocated to meet the shortfall in housing numbers whilst bringing vitality through development to the rural area.
As a registered charity, Varrier Jones Foundation (VJF) has a deep and intertwined legacy with the history of Papworth Everard (Papworth). A unique and large custodian in the village, VJF is able to approach development collaboratively and holistically, with the capacity to provide facilities and beneficial development for the community in targeted locations throughout the village. Therefore a master plan strategy spanning Parcels A and B represents a landscape led development which provides a sensitive and contextually appropriate addition to Papworth, responding to the site’s sensitive heritage and landscape constraints.
Site A is considered suitable for a landscape-led residential development of between 302-452 dwellings, subject to stakeholder engagement and statutory consultees involvement to shape the proposal and what scale of benefits are preferred. The site is located along the western side of the village and is enclosed by the A1198 bypass which acts as a defensible boundary and forms an enclosed parcel of land that can now have a planned and designed purpose put to it. The site would include affordable housing, landscaping, and a variety of open space. Cycle and pedestrian links would be retained and improved as part of the proposed development
Site B is the north western parcel and is proposed as land with potential for a primary school expansion or for community use, representing a demonstrable benefit to existing and future residents of Papworth Everard and an opportunity to enhance the vitality of this rural community.

The Varrier Jones Foundation object to Policy S/JH. The policy is unsound as it is not positively prepared, not justified, not effective and inconsistent with national policy.
These representations are supported by the enclosed Note on Housing Need and Supply Matters. This concludes that the proposed housing requirement of Policy S/JH is unsound because:
i. It is not positively prepared as it does not meet even the minimum local housing need of the standard method, let alone reflect the economic ambitions of the government as expressed through the Local Growth Plan or respond sufficiently to the acute need for affordable housing.
ii. It is not justified as it does not provide any justification for a housing requirement below the minimum local housing need of the standard method, it does not even consider providing for a level of housing which aligns with local and national economic growth ambitions, and it has not considered whether a greater number of homes should be provided to better respond to affordable housing needs.
iii. It will not be effective, as it will not meet housing needs, support local and national economic ambitions or deliver as much affordable housing as could sustainably be achieved.
iv. It is inconsistent with national policy as it does not meet the minimum local housing need of the standard method contrary to the requirements of paragraph 62 of the NPPF, and it does not support the planned economic growth contrary to the PPG (2a-040) and paragraph 86d of the NPPF, and it is not informed by a consideration of a greater housing requirement to better meet affordable housing needs contrary to the requirements of the PPG (2a-024).
In terms of the policy context, paragraph 69 of the NPPF (2024) notes an Authority may need to plan for greater housing growth above their identified need to reflect growth ambitions linked to economic development or infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024) confirms that planning policies should seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment. The draft Plan does not do this. This message is translated into HO2(b) of the NPPF (2026) and it is clear that housing requirements within Local Plans should be set higher than the figure identified within a housing needs assessment where appropriate. It is confirmed that such circumstances include where a higher housing requirement is necessary to reflect growth ambitions linked to economic investment or infrastructure investment. Whilst the GCLP will be assessed against the NPPF (2024), it is clear the direction being established by central government is one of growth, with a particular focus on Cambridge and the surrounding region.
This need for growth is evidenced by national, regional and authority level investment in infrastructure including the new Cambridge South Railway Station providing direct connectivity between Cambridge Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context, the commitment to East West Rail establishes the area as one benefiting from continued investment in major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by the Greater Cambridge Development Corporation (GCDC) set to deliver infrastructure first growth. We contend in order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for growth must be realised now within the emerging Local Plan.
The approach of the LPA may be that the GCDC will deliver the growth over-and-above the minimum provision in the Draft Local Plan, but; the GCDC is yet to receive plan-making powers; it will prepare a Plan after the adoption of the Draft GCLP; it will need to undertake formal consultation and examination in public in the normal way to lead to a formally adopted “successor” Plan. Such a successor Plan will be many years away, while the growth ambition is now. The GCLP needs to address growth now and not rely on a possible GCDC Plan.
The proposed housing requirement of just 48,069 homes in the GCLP, which reflects the minimum identified by the standard method, will clearly act to constrain the economic ambitions of the Local Growth Plan contrary to paragraph 86d of the NPPF. The Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026) provides further support for this position. Using the latest 2026 housing stock and affordability inputs, it identifies a Standard Method minimum of 2,290 homes per annum, or 48,090 homes over the Plan period, and records the CPCA’s position that at least 59,409 homes should be planned for to support economic growth. These findings reinforce the Varrier Jones Foundation’s existing case for a more ambitious housing requirement.
Furthermore, The Housing Delivery Addendum 2026 Update uses the Liverpool Approach to calculating housing need and seeks to argue that the Liverpool approach is appropriate notwithstanding the fact that it concludes that a five-year land supply will be able to be demonstrated using the standard Sedgefield approach. This is clearly inconsistent with the recommendations of national guidance (PPG 68-031). It is also not positively prepared as it serves to introduce a policy to reduce the requirement throughout the plan period rather than identifying a sufficient supply of deliverable sites to meet housing needs and support the government’s objectives. The Greater Cambridge Housing Need and Supply Matters (Bidwells, September 2026) outlines that the Sedgefield approach should be used as per government recommendation, however the report goes on to show that the authority can only demonstrate a 4.41 year supply under the Liverpool, or 4.06 years with Sedgefield anyway, and as such it is a moot point.
The fact that the GCLP is not planning for the level of growth necessary to support the economic ambitions of the Local Growth Plan, which align with the economic objectives of the government is underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the basis of standard economic forecasts which are inevitably trend-based and so do not account for economic potential of the area as is necessary to align with local and national economic ambitions. The EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the ‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could be achieved with step change in investment.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater job growth in the region will generate a derived demand for housing, creating an interdependency between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario. Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is acknowledged the Standard Method does not take into account the specific growth agenda and focus on Cambridge as an area of ‘supercharged growth’.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm Cambridge’s position as an area capable of supporting and delivering high growth. Within this context Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.
We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in stating the fact that average household sizes are now larger, leading to an increase in people of working age and more in-commuting which reduces the number of local people required to fill jobs created. We raise concern this is an unsustainable approach to development strategy and reflects a local housing market where many young people are unable to move out of their family homes and move closer to or within Cambridge where jobs are located at key existing and development employment centres such as CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to address the affordability of housing within Greater Cambridge by planning for increased growth and supply to reflect growing demand rather than embed the issue of increasing household size.
In doing so and making provision for increased housing stock in Greater Cambridge in sustainable locations would ensure the Local Plan promotes more suitable patterns of travel as required by paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys required for employment.

The Plan should not rely on the future Greater Cambridge Development Corporation to deliver growth beyond the current allocations. While the GCDC has been established, it has yet to secure plan-making powers and any formally adopted 'successor' plan is likely to be many years away. Given the immediate growth ambitions for Greater Cambridge, the Local Plan must address these requirements now to provide certainty, support investment, and ensure growth now. As such, suitable employment sites should be allocated to support a diverse range of jobs by type and location. One such site is Land to the east of Stirling Way, Papworth Everard, known as Parcel C (HELAA 2026 site ID 40429). Please note that this Site has been incorrectly recorded as Land to the west of Stirling Way in the 2026 HELAA Sites Register, however as shown by the Site Plan in the HELAA and appended to this submission, the land is to the east of Stirling Way.
Furthermore, the reference to 73,300 additional jobs should be treated as a minimum target rather than expressed, or even inferred, as a cap on growth beyond this number. As currently drafted, there is a risk that the figure could be interpreted as limiting future employment growth opportunities. The policy should make clear that the target represents a minimum level of employment growth and should not act as a constraint to the delivery of additional jobs where sustainable economic opportunities arise through acceptable developments at that time.

The Varrier Jones Foundation object to draft policy S/JH. Paragraph 69 of the NPPF (2024) is clear that Authorities need to plan for higher levels of growth than the Standard Method requirement to reflect growth ambitions linked to economic development and infrastructure investment. The draft plan does not do this. Cambridge and the surrounding region is central to the government’s ambition to ‘supercharge’ growth. The draft plan does not reflect this ambition and will not meet the government’s expectations.
This is backed by national, regional and authority level investment in infrastructure including the new Cambridge South Train Station providing direct connectivity between CBC and London, the granting of the Cambourne to Cambridge bus way and progression of Cambridge South East Transport to inquiry later this year. In a national context the commitment to East West Rail establishes the area as one benefiting from continued investment in major transport infrastructure. Growth envisioned by government is set to be realised and delivered by the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in order to ensure the plan is found sound the unique nature of Cambridge and its projected capacity for growth must be realised within the emerging Local Plan.
We acknowledge Policy S/JH identifies a housing need for Greater Cambridge of 48,069 over the plan period, which equates to 2,289 dwellings per annum, consistent to the Standard Method output for the identified housing need of Greater Cambridge. Notwithstanding the Employment and Housing Needs Update (EHNU) (2026) adopts the preferred employment scenario which will generate 73,248 jobs over the plan period which aligns to generating a housing need of 48,069 dwellings across the plan period. The EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the ‘higher growth scenario’ dismissed. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Draft Local Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
However it is noted the EHNU notes that the higher scenario could be achieved with step change in investment. Such a step change now seems likely for the district, with the advent of the Greater Cambridge Development Corporation (backed by £400 million of central government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario. Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is acknowledged the Standard Method does not take into account the specific growth agenda and focus on Cambridge as an area of ‘supercharged growth’.
Further Greater Cambridge has benefited from recent and will benefit from future planned major infrastructure development which establishes Greater Cambridge as a place of regional and national importance where growth should be accommodated. The East-West Rail DCO is anticipated to be submitted in 2027 which will deliver a new station at Cambourne and run services through the newly opened Cambridge South Station alongside the other two train stations in Cambridge. Further Cambourne to Cambridge Busway has now received consent and is anticipated to be delivered shortly. Cambridge South East Transport (CSET) also is set to proceeded inquiry shortly further demonstrating the ongoing commitment to the delivery of major transport infrastructure in the region to support future growth.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm Cambridge’s position as an area capable of supporting and delivering high growth. Within this context Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’.
The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.  
For these reasons, the Local Plan should consider utilising more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.