Greater Cambridge Local Plan: Proposed Submission

The representations seek amendments to Draft Policy S/JH: New Jobs and Homes by increasing the housing requirement above the current 48,069 dwellings and ensuring the Plan better reflects Greater Cambridge’s economic growth ambitions. It is argued that the Local Housing Need should be treated as a minimum rather than a target, particularly given the anticipated growth of the Cambridge Biomedical Campus and the wider knowledge economy. The modifications propose allocating additional deliverable and sustainable sites, including Land at Foxton, to provide greater flexibility, support higher job growth forecasts, improve housing affordability, and strengthen resilience against delays to major strategic allocations.
The representations also recommend revising the housing strategy and spatial distribution of growth to reduce reliance on large new settlements, which are considered high risk and potentially undeliverable within the plan period. Instead, the Plan should include a broader portfolio of sites in sustainable, rail-connected locations. Specifically, Land at Foxton should be allocated as a residential-led mixed-use development of approximately 1,500 homes, helping to diversify supply, support the Cambridge Biomedical Campus workforce, align housing with transport infrastructure, and improve the soundness, effectiveness and deliverability of Policy S/JH.

The following text is taken from Chapter 2 and Chapter 3 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is read as a whole, to provide a comprehensive response to the Plan and Draft Policy S/JH in particular. On this basis, please refer to the attached representations for a comprehensive response to this Policy.
4.2 Site Context
4.2.1 Land at Foxton is identified on the Site Location Plan provided at Appendix A.
4.2.2 The Site is located to the north west of Foxton village, directly adjacent to the settlement boundary and Foxton railway station. The Site falls outside of the Green Belt.
4.2.3 Foxton is designated as a Group Village in the adopted Greater Cambridge Local Plan and the Draft Plan, but this does not reflect the potential of the village to support growth in South Cambridge, close to the Cambridge Biomedical Campus (CBC), and the wider Cambridge region. This is explored in more detail in the subsequent Section.
4.2.4 Foxton is located approximately 11 kilometres south-west of Cambridge and approximately 9 kilometres south-west of the CBC, one of Europe’s leading life science and healthcare clusters.
4.2.5 The Site is in a highly sustainable location adjacent to Foxton railway station on the Cambridge to London mainline. Foxton benefits from a direct rail connection with regular service to Cambridge South (7 minutes), Cambridge City Centre (13 minutes) and London (circa. 1 hour).
4.2.6 CBC is located at the newly opened Cambridge South Station, easily accessible from the Site. The Site's relationship with one of the UK's most important employment locations is, therefore, very strong. The Site also sits on the A10 corridor, a key transport route south – north into Cambridge.
Foxton Station
4.2.7 Paragraph 77 of the 2024 NPPF recognises that ‘the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes)’.
4.2.8 Land at Foxton is an extension to an existing village and is adjacent to a train station. The Site accords with paragraph 77 of the 2024 NPPF on this basis.
4.2.9 Although the Draft Plan is being produced in accordance with the 2024 NPPF and so the 2026 adopted NPPF is not relevant for the purpose of plan making, it is material that the Government has taken the ambitions of paragraph 77 further and introduced what it describes as: “a default ‘yes’ for homes within reasonable walking distance of well-connected stations” in the 2026 NPPF. This has been a theme of the Government’s growth ambitions and approach to planning policy reflected originally in the December 2025 Draft NPPF.
4.2.10 Land at Foxton is located directly adjacent to Foxton railway station, which underpins the suitability of the Site for development. The strategic value of the Site has, therefore, been ratified by the 2026 NPPF. For clarity, we consider how Land at Foxton accords with Policy S5 of the latest NPPF below.
4.2.11 Policy S5 (Principle of Development Outside Settlements) of the 2026 NPPF prescribes the criteria for approving residential development adjacent to well-connected train stations. It is clear in stating that: ‘these should be approved, unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in this Framework’. This is a strong presumption in favour of developing sites that meet the prescribed criteria.
4.2.12 An assessment of the suitability of Land at Foxton for residential and mixed-use development against criterion of Policy S5 is provided in Table 1 below.
Table 1 – Assessment of Land at Foxton in respect of the 2026 NPPF Policy S5
Policy S5 Part H Criteria Assessment of Land at Foxton
i. Be within reasonable walking distance of a well-connected station (applying the definitions in the glossary at Annex B); The developable area of the Site is within the prescribed 800m walking distance and 10-minute walking time to the station. Foxton Station is within the Top 80 Travel to Work Area with a frequency of service that adequately serves key locations such as Cambridge South, Cambridge and London. The Site is also a logical location should further investment be made into the frequency of service and has more than reasonable prospects of being served by an increased frequency in the future.
ii. Be physically well-related to the station or the settlement within which the station is located; The Site is physically well related to the station and the settlement boundary. It is just outside the settlement boundary and directly adjacent to the station. Its relationship to both is excellent.
iii. Be of a scale which can be accommodated taking into account the existing or proposed availability of infrastructure; and The Site will secure an appropriate level of infrastructure to ensure the proposed scale of development can be suitably accommodated. The Site presents a unique opportunity to deliver a self-sustaining development whilst facilitating wider infrastructure improvements that will benefit surrounding the local community and the wider region.
iv. Not prejudice any proposals for long-term comprehensive development in the same location The Site would not prejudice any proposals for long term comprehensive development in the same location as none exist.

4.2.13 It is clear that the Site aligns with the 2026 NPPF’s strong presumption in favour of developing sites that are adjacent to well-connected train stations. Taking this into account, Land at Foxton can clearly be identified as a logical location for residential-led mixed use development.
4.2.14 The Site is suitable for inclusion as an allocation in the Draft Plan on the basis that is complies with paragraph 77 of the 2024 NPPF and Policy S5 of the 2026 NPPF.
4.2.15 The housing strategy should be reviewed to consider the allocation of alternative sites, with due consideration given to those in well-connected sustainable locations, to help support housing growth in the region.
Cambridge Biomedical Campus (CBC)
4.2.16 The Cambridge Biomedical Campus (CBC) is one of Europe's leading centres for healthcare, life sciences, biomedical research and education. It brings together world-class research institutions, teaching hospitals, universities and global life sciences businesses in a single location, creating a unique ecosystem that facilitates the translation of research into clinical practice and patient care.
4.2.17 The Campus is recognised by the UK Government as a key component of the Cambridge life sciences cluster and a critical asset in supporting ambitions for Cambridge to become a global science and innovation powerhouse. The CBC is the largest employer in the region, with plans to expand further. The Case for Cambridge (March 2024) sets out the UK Government’s ambition to position Cambridge as a world-leading centre for science, research, and innovation, underpinning national economic growth. It highlights CBC as a key part of that, but emphasises that Cambridge’s success depends on delivering sustainable, infrastructure-led growth that balances homes, jobs, and environmental constraints.
4.2.18 Housing and infrastructure constraints risk limiting the ability of CBC to expand and attract talent. Housing delivery has not kept pace with job creation, resulting in severe affordability and availability pressures. Employment at CBC is anticipated to grow from 22,000 to 40,000 in the coming years. Additional housing demand is therefore significant. This will require a substantial increase in local housing to sustain the skilled workforce essential to its global competitiveness.
4.2.19 The Cambridge Biomedical Campus Housing Study (Lichfields, 2024) is clear in its assessment of CBC’s housing need:
 38% of CBC workers are stretched in meeting current housing costs;
 30% of CBC workers are unable to afford rents in the open market;
 Entry level house prices in Cambridge are 13.7 times earnings for workers at CBC (increasing to 14.8 times earnings for those on lower incomes in the health sector);
 14,000 - 16,000 affordable homes are required to meet current and future needs; and
 40% of CBC workers current dissatisfied with their commute.
4.2.20 Therefore, the scale of the problem is evident. If the Greater Cambridge health and life sciences success story is to be realised, in particular at CBC, then GCSP must match economic growth with housing delivery. Land at Foxton is one of the very few locations capable of meeting this need in a timely and sustainable way.
4.2.21 The Site’s proximity to Foxton Station, combined with the direct rail connection to the new Cambridge South Station (7 minutes and two services an hour), makes it exceptionally well connected to the Campus. The CBC Housing Study highlights that 40% of employees are dissatisfied with their current commute. The reliability, frequency and speed of service from Foxton to CBC would undoubtedly improve this.
4.2.22 The development can deliver in the region of 1,500 homes at policy compliant affordable levels to help CBC overcome its greatest barrier to growth: a lack of housing. This housing would include accessible, affordable homes for key workers, researchers, clinicians and specialist staff. The importance of this in the context of Cambridge’s growth ambitions should not be underestimated. It is key to the success of CBC and the wider region.
4.2.23 Land at Foxton is uniquely positioned in one of the most accessible locations in the region for strategic growth, in line with the Government’s mandate for growth and at a scale to match the pressures within the science and technology sectors.
4.2.24 The Economic Case provided at Appendix C sets out the importance of this issue, and the critical role that Land at Foxton will play in the future of the CBC.
4.3 Development Potential
4.3.1 The proposed vision for Land at Foxton is sets out in the Vision Document provided at Appendix B. The vision for the Site has evolved through previous iterations of the Local Plan making process.
4.3.2 The Site has an area of approximately 98 hectares and is located between the villages of Foxton, Shepreth, and Barrington, to the north west edge of Foxton. The development of the Site for a residential led, mixed-use neighbourhood of new homes, employment opportunities, community facilities and extensive green infrastructure will allow Foxton to reach its potential as a strategic location in South Cambridgeshire, centred on a highly accessible and well-connected station.
4.3.3 At its heart, the development will deliver:
 In the region of 1,500 new residential dwellings, in a mix of housing types and including significant affordable housing;
 Exceptional walking and cycling connectivity, within the Site and beyond to surrounding villages;
 New mixed-use development to complement existing facilities in Foxton, potentially including a mix of commercial, employment and community related land uses;
 An integrated multi-modal travel and mobility hub adjacent to Foxton station, enhancing accessibility and promoting sustainable travel modes;
 Education provision to serve new and existing residents;
 Improvements to water quality and infrastructure to serve the development and local area;
 The opportunity to work with other stakeholders to address the congestion and conflicts where the London-Cambridge railway line crosses the A10;
 An improved accessibility solution around Foxton station and the A10; and
 A substantial quantum of open and accessible green space, addressing local green infrastructure deficiencies and providing a significant Biodiversity Net Gain.
4.3.4 The development of the Site for a residential led, mixed-use neighbourhood of new homes, employment opportunities, community facilities and extensive green infrastructure will deliver regionally significant development in the south of Cambridge in line with the Government mandate for the region.
4.3.5 The vision is to create an enduring place where people of all ages and backgrounds can live, work, learn and thrive in close proximity to Cambridge and its innovation economy. The delivery of much-needed homes, including affordable housing, will leave a lasting legacy of improvement to the south of Cambridge with positive social, environmental and economic impact.
4.3.6 The development will be water-sensitive and climate-resilient throughout, with an innovative approach to future foul and potable water management. The large quantum of open and accessible green space to be delivered on site will aid this, addressing local green infrastructure deficiencies and providing a significant Biodiversity Net Gain.
4.3.7 Finally, and importantly, the development can facilitate improvements, including infrastructure improvements, to relieve congestion and conflicts where the London-Cambridge railway line crosses the A10.
4.3.8 It is well understood that this bottleneck has severe local impacts that detract from the quality of life of local people, as well as having wider social, economic and environmental impacts for the wider region.
4.3.9 Development of the Site creates unparalleled opportunity for Axis to work with the local community and other stakeholders, including Network Rail, Cambridge County Council, the forthcoming Development Corporation, and others to address this long-standing issue.
4.3.10 In this way, the vision for Land at Foxton supports significant growth and high-quality placemaking. The site is uniquely positioned to help deliver the Government’s ambition for sustainable growth in Greater Cambridge and providing a new community in a highly accessible location, outside the Green Belt, that will contribute directly to national and regional objectives while benefitting the local environment and community.
5. Housing Delivery in Cambridge
5.1.1 This Section assesses GCSP’s approach to housing delivery in the Draft Plan.
5.2 Housing Requirement
5.2.1 The Draft Plan identifies a Local Housing Need (LHN) based on the Government’s standard method of 2,289 dwellings per annum (dpa), equating to 48,069 homes required over the plan period (Draft Policy S/JH).
5.2.2 The Draft Plan sets out how these numbers will be met in Draft Policy S/DS. This is restated in Table Two below.
Table 2 – Total Housing Supply to Meet Identified Housing Need for 2024-2045
Homes to be delivered Homes 2024-2045
Current Supply 38,378
New Sites 13,654
Total supply 52,032
Headroom provided by total supply in relation to housing need 3,963 (8.2%)

5.2.3 The Draft Plan does, therefore, increase the housing target beyond the base LHN by providing a total supply of 52,032 homes. This 8.2% uplift is supported in principle. However, we would urge GCSP to consider that there is potential for additional growth within Greater Cambridge, as per the previously submitted Regulation 18 representations.
5.2.4 A housing strategy should not be considered effective simply because its total supply equals or marginally exceeds the numerical requirement across the plan period. The LHN should be a minimum requirement. In Greater Cambridgeshire, the economic drivers mean that the ambition must be to maximise housing delivery to support good economic growth in a sustainable way. The Local Plan should seek to deliver more housing to exceed calculated LHN in a wider geographical spread than is currently proposed. Currently, housing delivery is focused in the north of Cambridge, which creates an unsustainable imbalance. Furthermore, what matters is whether the homes are likely to be delivered when required and whether the strategy contains sufficient alternative supply if identified sites are delayed, reduced in capacity or affected by infrastructure constraints.
5.2.5 On this basis, there are several key indicators suggesting that a higher housing requirement would be justified in this case, namely:
 To adequately respond to and support Greater Cambridge’s economic growth potential and meet an unmet need for market and affordable housing;
 To provide sufficient flexibility to manage delivery risk, reducing the current reliance on a number of large and complex strategic new settlements; and
 To make effective use of opportunities in sustainable, well-connected locations, particularly in the south and south west.
5.3 Economic Growth Opportunities
5.3.1 The Draft Plan identifies a need to provide 73,300 additional jobs to support the Greater Cambridge’s knowledge intensive sectors and provide a diverse range of local jobs. GCSP have taken a central forecast from the Greater Cambridge Employment and Housing Evidence Update 2025 (EHEU) to underpin the employment figures in the Draft Plan. This assumes growth of around 3,500 additional jobs per annum or more through to 2045.
5.3.2 However, the EHEU identified that a higher growth forecast was likely, placing greater weight on rapid growth in the recent past, particularly in key sectors. This will be reinforced by the Government’s mandate for growth in the region.
5.3.3 On this basis, there is likely to be demand for more jobs than currently planned for. This is not reflected in the Draft Plan, but is nonetheless a realistic scenario. Given the ambitions of the Government and the Cambridge Growth Company, and the significant investment (£400 million of Government funding announced 23 October 2025) into Cambridge to support its future growth, there is no doubt that there will be additional growth.
5.3.4 The EHEU concludes that the Government’s Standard Method would support the forecast for future jobs. However, it is evident that the Draft Plan has not catered for the high growth scenario that is more likely to take place.
5.3.5 Additional growth to support the ambitions of the Government and Cambridge Growth Company should be incorporated into the Draft Plan. The Plan should identify a higher housing requirement and allocate additional deliverable and developable sites, including Land at Foxton, to provide greater certainty to housing delivery throughout the plan period.
5.4 Reliance on New Settlement Sites
5.4.1 The Draft Plan substantially relies on a limited number of large, strategic scale sites to meet Greater Cambridge’s housing requirement. While strategic development will be necessary on some scale to support Cambridge’s future growth, the concentration of housing delivery included in the Draft Plan within complex, long-term schemes creates a significant risk to the effectiveness and resilience of the Plan’s development strategy.
5.4.2 The Draft Plan caters for housing distribution of the following nature (Figure 9 of Draft Plan):
 11% in the Cambridge Urban Area (including windfalls);
 30% on the Edge of Cambridge;
 44% in new settlements; and
 15% in the Rural Area (including windfalls).
5.4.3 Large new settlements can deliver substantial numbers of homes and important supporting infrastructure, but delivery commonly depends upon the timely resolution of complex matters. A reliance of 44% housing delivery in new settlements is heavily weighted and requires the resolution of strategic scale infrastructure alongside.
5.4.4 Consequently, even relatively modest delays affecting one or more major allocations could have a disproportionate effect on the overall housing trajectory. This is a precarious strategy that will fail to deliver timely housing delivery.
5.4.5 Capacity and delivery expectations associated with strategic sites can change materially as technical evidence and infrastructure requirements are refined. It would therefore be inappropriate for the Plan to assume that every strategic allocation will deliver precisely in accordance with its stated capacity and anticipated trajectory over a 21-year plan period.
5.4.6 There must also be consideration given to the timing of housing trajectory delivery, rather than simply total quantity. The trajectory shown in the Draft Plan relies upon peaks in delivery, while delivery is expected to fall below the annual housing need in several years. Indeed, the trajectory highlights there to be no substantial delivery from new allocations prior to 2032/33. This demonstrates the underlying concern that the Plan’s ability to meet its requirement depends upon a limited number of strategic sites achieving substantial and sustained rates of delivery within particular periods (2032/33 onwards). This is a precarious model for housing delivery that does not guarantee deliverability over the plan period, rendering the Draft Plan ineffective.
5.4.7 The identification of sufficient housing land does not, in itself, establish that the Draft Plan will be effective. A sound strategy must demonstrate that homes can be delivered consistently and at the point at which they are needed. It should also provide sufficient flexibility to respond to delays, changes in infrastructure programmes, reduced site capacities, slower market absorption and other unforeseen circumstances. Where the requirement is treated as a minimum target, but the supply is heavily concentrated within a small number of complex locations, there is limited scope to compensate for under-delivery.
5.4.8 The Lichfields Start to Finish research document (February 2025), identifies that on average it takes 6.6 years from validation of the first planning application to the first dwelling being completed on scheme of 2,000 or more dwellings.
5.4.9 Table Three below shows the delivery of new settlements during the emerging Plan period, as described in the Draft Plan. Four of the new settlements over 2,000 units are yet to receive planning permission. It is our understanding that three of these (Cambourne North, Cambridge East and Grange Farm) are yet to have formal planning applications submitted. This totals 9,050 units (17% of the total supply).
5.4.10 If we assume that the majority of applications do not come forward until after the Draft Plan is adopted (assuming adoption in its current form), then the earliest these applications are likely to be submitted is the 2028/29 year. Taking the Lichfield’s analysis into account, this would mean most new settlement sites will not deliver first homes until 2034/35 – 2035/36.
5.4.11 This assumption is also made on the basis that the relevant sites are available and deliverable at the earliest opportunity. All these sites have significant infrastructure requirements which are only likely to further restrict and delay delivery.
5.4.12 There are, therefore, significant question marks about the ability of the Draft Plan to meet the overall housing target in a timely manner. Our expectation is that if the Draft Plan were to be adopted in its current form, then the GCSP would quickly fall behind its housing requirement targets both in terms of Five-Year Housing Land Supply (5YHLS) and Housing Delivery Test (HDT).
5.4.13 Indeed, several of the committed new settlement sites have fallen behind in their delivery. It would be reasonable to include a circa 10-20% lapse rate against all planning permissions that have not started to account for a reasonable assumption of delay, especially in the current economic climate. Applying a 10% lapse rate to the 18,219 committed homes would reduce the supply by 1,822 within the plan period. This is 80% of the annual LHN and 46% of the headroom allowed for in the Draft Plan. Depending on the timing of this impact, this could further expose the GCSP’s 5YHLS position or HDT score and undermines the entire housing trajectory.
Table 3 – Delivery of New Settlements During Emerging Plan Period
Settlement Number of Homes to be delivered in Plan Period Total Number of Dwellings Extant Permission Percentage of Homes Delivered in Plan Period
Bourn Airfield 3,500 3,500 Yes 100%
Waterbeach New town 5,721 10,975 Yes 52%
Northstowe 6,382 10,180 Yes 63%
Eddington (Phase 1) 2,616 5,500 Yes 48%
TOTAL 18,219
Cambourne North 2,550 13,000 No 20%
Cambridge East 3,950 8,000 No 49%
Grange Farm 2,550 4,500 No 57%
Eddington (Phase 2) 2,500 5,500 No 45%
TOTAL 11,550

5.4.14 The GCSP’s housing trajectory is also reliant on the new settlements of 2,000+ dwellings each delivering 300 units per annum (with an initial five years and final five years at reduced rates of 50, 100, 150, 200 and 250 dwellings). This level of delivery far exceeds the highest average annual build-out rate for schemes of 2,000+ dwellings found in the Lichfields Start to Finish report of 100-188 dpa. This further exacerbates the precarious and problematic approach to housing trajectory included in the Draft Plan.
5.4.15 In its current form, the Draft Plan fails to provide a strategy which would meet the area’s objectively assessed needs within the plan period. The strategy is not deliverable and so the Draft Plan fails to be effective or positively prepared in this way.
5.4.16 It is evident that the Plan would benefit from a more diverse portfolio of allocated sites, comprising a range of geographies, scales, markets and delivery models. This would reduce dependence on individual strategic locations and enable housing delivery to be maintained if one or more major allocations were delayed. Such diversification would not undermine the role of the Plan’s existing strategic sites. Rather, it would improve the overall resilience of the strategy and increase confidence that the minimum housing requirement can be met in a full and timely manner.
5.4.17 Land at Foxton is particularly well suited to fulfilling this role. The Site has previously been identified through the Housing and Employment Land Availability Assessment as having capacity for approximately 1,500 homes and employment floorspace. It adjoins a well-connected railway station, lies outside the Cambridge Green Belt and is capable of delivering a comprehensively planned, residential-led mixed-use community supported by new infrastructure, services, employment opportunities and extensive green infrastructure.
5.4.18 The Site would also introduce an additional source of supply within close proximity to Cambridge and the CBC, the benefits of which have already been set out in these representations.
5.4.19 Importantly, Land at Foxton should not be viewed simply as another large strategic site replicating the risks inherent elsewhere in the strategy. Its scale and location differentiate it and make it truly available and deliverable without the need for lengthy processes such as Green Belt release or transport infrastructure required to serve new settlements. The Site would complement the other allocations and provide greater certainty to GCSP’s housing delivery.
5.4.20 Furthermore, it is uniquely located to provide the opportunity to facilitate improvements to relieve the congestion and conflicts at the Foxton level crossing.
5.4.21 The omission of the Site is a missed opportunity by GCSP to introduce greater flexibility into the housing strategy and address a long-standing bottleneck for the benefit of the local community and the wider region. We urge them to reconsider this as part of this Local Plan Review.
5.5 Spatial Strategy
5.5.1 In identifying its preferred strategy, GCSP considered a range of potential sources of housing supply. Chapter Four of the Sustainability Appraisal (SA) sets out the various strategic spatial options explored by GCSP in preparing the Draft Plan. Since 2019, there has been a cumulative total of 24 different iterations of spatial options.
5.5.2 Despite some exploration of growth opportunities around transport nodes, there is no appreciation or consideration for the sustainability of sites along key southern transport routes. Indeed, the SA references the latest strategic spatial options as having ‘limited development distributed across Rural Centres, Minor Rural Centres, and Group Villages with very good Public Transport Access’ in both the southern cluster and the rest of the rural area villages.
5.5.3 The Plan’s own evidence, therefore, recognises that public transport accessibility and proximity to employment are relevant considerations in determining the most sustainable distribution of growth. This accords with paragraph 77 of the 2024 NPPF and Policy S5 of the 2026 NPPF regarding siting development in sustainable and accessible locations.
5.5.4 Despite this, there is a simple dismissal of sites for consideration along well-connected and strategically located routes, with connections to nationally important economic nodes such as Cambridge, South Cambridge, London, and the wider Oxford-Cambridge arc. The spatial strategy does not make effective use of the development opportunities available at the most sustainable rural transport locations.
5.5.5 The spatial strategy directs a substantial proportion of growth towards the Cambridge urban area and the edge of Cambridge in the north. These locations are proposed to play an important role in housing delivery, but as identified above, this is not guaranteed. The Plan does not establish a sufficiently balanced distribution of growth across Greater Cambridge. This is evident in Figure 1 below.
Figure 1 – Illustrative Map Showing Locations of New Housing Development from 2024 to 2045 (Draft Plan Figure 6)

5.5.6 The Draft Plan’s spatial strategy creates several concerns:
 It increases dependence on a narrow range of complex strategic locations and related infrastructure in those areas;
 It provides insufficient flexibility if strategic infrastructure is delayed;
 It limits opportunities to diversify housing delivery across different markets;
 It does not make full use of existing railway stations and transport corridors; and
 It is not aligned with comprehensively planned employment growth.
5.5.7 The Draft Plan does not make sufficiently effective use of land in highly accessible locations. Figure 2 below makes this point clear, in that when compared with Figure 1 there appears a clear disparity between the delivery of major transport projects and corresponding housing delivery in the south west of Cambridge.
Figure 2 – Map of Existing and Proposed Major Transport Projects (Draft Plan Figure 10)

5.5.8 A more positive strategy would recognise the role that rail-connected development can play in reducing reliance on the private car, supporting access to employment and aligning housing with infrastructure.
5.5.9 These are compelling reasons to supplement the Draft Plan with a wider portfolio of sustainable sites offering different locations, scales, markets and delivery characteristics that better align with strategic infrastructure delivery. This would better align the Draft Plan with paragraph 77 of the 2024 NPPF and reflect the ambitions of Policy S5 of the 2026 NPPF.
5.5.10 On this basis, to make the Draft Plan sound and to make it consistent with national policy, the GCSP should broaden the portfolio of allocations to recognise the importance of sites close to railway stations, and to include a more balanced mix of locations, scales and delivery models to better align the spatial strategy with logical locations for growth.
5.5.11 If the Draft Plan was to be adopted in its current form, it would fail the tests of soundness as a plan that is:
 Not positively prepared – unable to meet the area’s objectively assessed needs;
 Unjustified – with an inappropriate housing strategy which does not consider reasonable alternatives based on robust evidence;
 Ineffective – as the housing trajectory is undeliverable within the plan period; and
 Inconsistent with national policy – without consideration for siting new development in sustainable locations that are well located, currently supported by the necessary infrastructure and facilities, and include a genuine choice of transport modes.
5.5.12 Draft Policy S/JH: New Jobs and Homes sets out the need for jobs and homes in Greater Cambridge between 2024-2045. The Draft Plan plans for 73,300 additional jobs required as well as 48,069 homes meeting the needs for the total population.
5.5.13 Axis has significant concerns with the soundness of the approach taken to providing new jobs and homes in the Draft Plan. This Policy is addressed in full in the preceding section of these representations.

The representations recommend that Draft Policy S/DS be amended to create a more flexible, resilient and deliverable development strategy, with particular emphasis on allocating Land at Foxton and making better use of sustainable, rail-connected locations.
Key recommended modifications are:
- Allocate Land at Foxton within the development strategy as a sustainable, deliverable site capable of providing around 1,500 homes, employment opportunities, supporting infrastructure and community facilities.
- Increase the housing requirement and housing supply to better support Greater Cambridge's economic growth ambitions, particularly the expansion of the Cambridge Biomedical Campus and wider life sciences sector.
- Diversify the portfolio of allocated sites to reduce reliance on a small number of large and complex new settlements.
- Reduce dependency on strategic new settlements where delivery is contingent on significant infrastructure requirements and lengthy lead-in times.
- Provide greater flexibility and contingency within the housing strategy to ensure housing delivery can continue if major allocations are delayed, reduced in capacity or fail to come forward as anticipated.
- Rebalance the spatial distribution of growth by directing a greater proportion of development towards sustainable locations in the south and south-west of Cambridge, rather than concentrating growth primarily in the north.
- Give greater weight to sites adjacent to well-connected railway stations, reflecting Paragraph 77 of the 2024 NPPF and Policy S5 of the 2026 NPPF.
- Make better use of existing transport infrastructure, including rail corridors and stations, to support transit-oriented development and reduce reliance on private car travel.
Recognise rail-connected locations as logical locations for growth and incorporate them more fully into the allocation strategy.

Align housing growth more closely with employment growth, particularly around the Cambridge Biomedical Campus and Cambridge South Station.

Include a broader mix of site sizes, locations and delivery models to improve resilience and confidence in housing delivery throughout the plan period.

Overall, the recommended amendment is that Policy S/DS should move away from an over-reliance on large new settlements and instead allocate a wider range of deliverable sites, including Foxton, to create a more balanced, robust and nationally policy-compliant development strategy.

The following text is taken from Chapter 2 and Chapter 3 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy S/DS in particular. On this basis, please refer to the attached representations for a comprehensive response.
5.7 Site Context
5.7.1 Land at Foxton is identified on the Site Location Plan provided at Appendix A.
5.7.2 The Site is located to the north west of Foxton village, directly adjacent to the settlement boundary and Foxton railway station. The Site falls outside of the Green Belt.
5.7.3 Foxton is designated as a Group Village in the adopted Greater Cambridge Local Plan and the Draft Plan, but this does not reflect the potential of the village to support growth in South Cambridge, close to the Cambridge Biomedical Campus (CBC), and the wider Cambridge region. This is explored in more detail in the subsequent Section.
5.7.4 Foxton is located approximately 11 kilometres south-west of Cambridge and approximately 9 kilometres south-west of the CBC, one of Europe’s leading life science and healthcare clusters.
5.7.5 The Site is in a highly sustainable location adjacent to Foxton railway station on the Cambridge to London mainline. Foxton benefits from a direct rail connection with regular service to Cambridge South (7 minutes), Cambridge City Centre (13 minutes) and London (circa. 1 hour).
5.7.6 CBC is located at the newly opened Cambridge South Station, easily accessible from the Site. The Site's relationship with one of the UK's most important employment locations is, therefore, very strong. The Site also sits on the A10 corridor, a key transport route south – north into Cambridge.
Foxton Station
5.7.7 Paragraph 77 of the 2024 NPPF recognises that ‘the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes)’.
5.7.8 Land at Foxton is an extension to an existing village and is adjacent to a train station. The Site accords with paragraph 77 of the 2024 NPPF on this basis.
5.7.9 Although the Draft Plan is being produced in accordance with the 2024 NPPF and so the 2026 adopted NPPF is not relevant for the purpose of plan making, it is material that the Government has taken the ambitions of paragraph 77 further and introduced what it describes as: “a default ‘yes’ for homes within reasonable walking distance of well-connected stations” in the 2026 NPPF. This has been a theme of the Government’s growth ambitions and approach to planning policy reflected originally in the December 2025 Draft NPPF.
5.7.10 Land at Foxton is located directly adjacent to Foxton railway station, which underpins the suitability of the Site for development. The strategic value of the Site has, therefore, been ratified by the 2026 NPPF. For clarity, we consider how Land at Foxton accords with Policy S5 of the latest NPPF below.
5.7.11 Policy S5 (Principle of Development Outside Settlements) of the 2026 NPPF prescribes the criteria for approving residential development adjacent to well-connected train stations. It is clear in stating that: ‘these should be approved, unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in this Framework’. This is a strong presumption in favour of developing sites that meet the prescribed criteria.
5.7.12 An assessment of the suitability of Land at Foxton for residential and mixed-use development against criterion of Policy S5 is provided in Table 1 below.
Table 1 – Assessment of Land at Foxton in respect of the 2026 NPPF Policy S5
Policy S5 Part H Criteria Assessment of Land at Foxton
i. Be within reasonable walking distance of a well-connected station (applying the definitions in the glossary at Annex B); The developable area of the Site is within the prescribed 800m walking distance and 10-minute walking time to the station. Foxton Station is within the Top 80 Travel to Work Area with a frequency of service that adequately serves key locations such as Cambridge South, Cambridge and London. The Site is also a logical location should further investment be made into the frequency of service and has more than reasonable prospects of being served by an increased frequency in the future.
ii. Be physically well-related to the station or the settlement within which the station is located; The Site is physically well related to the station and the settlement boundary. It is just outside the settlement boundary and directly adjacent to the station. Its relationship to both is excellent.
iii. Be of a scale which can be accommodated taking into account the existing or proposed availability of infrastructure; and The Site will secure an appropriate level of infrastructure to ensure the proposed scale of development can be suitably accommodated. The Site presents a unique opportunity to deliver a self-sustaining development whilst facilitating wider infrastructure improvements that will benefit surrounding the local community and the wider region.
iv. Not prejudice any proposals for long-term comprehensive development in the same location The Site would not prejudice any proposals for long term comprehensive development in the same location as none exist.

5.7.13 It is clear that the Site aligns with the 2026 NPPF’s strong presumption in favour of developing sites that are adjacent to well-connected train stations. Taking this into account, Land at Foxton can clearly be identified as a logical location for residential-led mixed use development.
5.7.14 The Site is suitable for inclusion as an allocation in the Draft Plan on the basis that is complies with paragraph 77 of the 2024 NPPF and Policy S5 of the 2026 NPPF.
5.7.15 The housing strategy should be reviewed to consider the allocation of alternative sites, with due consideration given to those in well-connected sustainable locations, to help support housing growth in the region.
Cambridge Biomedical Campus (CBC)
5.7.16 The Cambridge Biomedical Campus (CBC) is one of Europe's leading centres for healthcare, life sciences, biomedical research and education. It brings together world-class research institutions, teaching hospitals, universities and global life sciences businesses in a single location, creating a unique ecosystem that facilitates the translation of research into clinical practice and patient care.
5.7.17 The Campus is recognised by the UK Government as a key component of the Cambridge life sciences cluster and a critical asset in supporting ambitions for Cambridge to become a global science and innovation powerhouse. The CBC is the largest employer in the region, with plans to expand further. The Case for Cambridge (March 2024) sets out the UK Government’s ambition to position Cambridge as a world-leading centre for science, research, and innovation, underpinning national economic growth. It highlights CBC as a key part of that, but emphasises that Cambridge’s success depends on delivering sustainable, infrastructure-led growth that balances homes, jobs, and environmental constraints.
5.7.18 Housing and infrastructure constraints risk limiting the ability of CBC to expand and attract talent. Housing delivery has not kept pace with job creation, resulting in severe affordability and availability pressures. Employment at CBC is anticipated to grow from 22,000 to 40,000 in the coming years. Additional housing demand is therefore significant. This will require a substantial increase in local housing to sustain the skilled workforce essential to its global competitiveness.
5.7.19 The Cambridge Biomedical Campus Housing Study (Lichfields, 2024) is clear in its assessment of CBC’s housing need:
 38% of CBC workers are stretched in meeting current housing costs;
 30% of CBC workers are unable to afford rents in the open market;
 Entry level house prices in Cambridge are 13.7 times earnings for workers at CBC (increasing to 14.8 times earnings for those on lower incomes in the health sector);
 14,000 - 16,000 affordable homes are required to meet current and future needs; and
 40% of CBC workers current dissatisfied with their commute.
5.7.20 Therefore, the scale of the problem is evident. If the Greater Cambridge health and life sciences success story is to be realised, in particular at CBC, then GCSP must match economic growth with housing delivery. Land at Foxton is one of the very few locations capable of meeting this need in a timely and sustainable way.
5.7.21 The Site’s proximity to Foxton Station, combined with the direct rail connection to the new Cambridge South Station (7 minutes and two services an hour), makes it exceptionally well connected to the Campus. The CBC Housing Study highlights that 40% of employees are dissatisfied with their current commute. The reliability, frequency and speed of service from Foxton to CBC would undoubtedly improve this.
5.7.22 The development can deliver in the region of 1,500 homes at policy compliant affordable levels to help CBC overcome its greatest barrier to growth: a lack of housing. This housing would include accessible, affordable homes for key workers, researchers, clinicians and specialist staff. The importance of this in the context of Cambridge’s growth ambitions should not be underestimated. It is key to the success of CBC and the wider region.
5.7.23 Land at Foxton is uniquely positioned in one of the most accessible locations in the region for strategic growth, in line with the Government’s mandate for growth and at a scale to match the pressures within the science and technology sectors.
5.7.24 The Economic Case provided at Appendix C sets out the importance of this issue, and the critical role that Land at Foxton will play in the future of the CBC.
5.8 Development Potential
5.8.1 The proposed vision for Land at Foxton is sets out in the Vision Document provided at Appendix B. The vision for the Site has evolved through previous iterations of the Local Plan making process.
5.8.2 The Site has an area of approximately 98 hectares and is located between the villages of Foxton, Shepreth, and Barrington, to the north west edge of Foxton. The development of the Site for a residential led, mixed-use neighbourhood of new homes, employment opportunities, community facilities and extensive green infrastructure will allow Foxton to reach its potential as a strategic location in South Cambridgeshire, centred on a highly accessible and well-connected station.
5.8.3 At its heart, the development will deliver:
 In the region of 1,500 new residential dwellings, in a mix of housing types and including significant affordable housing;
 Exceptional walking and cycling connectivity, within the Site and beyond to surrounding villages;
 New mixed-use development to complement existing facilities in Foxton, potentially including a mix of commercial, employment and community related land uses;
 An integrated multi-modal travel and mobility hub adjacent to Foxton station, enhancing accessibility and promoting sustainable travel modes;
 Education provision to serve new and existing residents;
 Improvements to water quality and infrastructure to serve the development and local area;
 The opportunity to work with other stakeholders to address the congestion and conflicts where the London-Cambridge railway line crosses the A10;
 An improved accessibility solution around Foxton station and the A10; and
 A substantial quantum of open and accessible green space, addressing local green infrastructure deficiencies and providing a significant Biodiversity Net Gain.
5.8.4 The development of the Site for a residential led, mixed-use neighbourhood of new homes, employment opportunities, community facilities and extensive green infrastructure will deliver regionally significant development in the south of Cambridge in line with the Government mandate for the region.
5.8.5 The vision is to create an enduring place where people of all ages and backgrounds can live, work, learn and thrive in close proximity to Cambridge and its innovation economy. The delivery of much-needed homes, including affordable housing, will leave a lasting legacy of improvement to the south of Cambridge with positive social, environmental and economic impact.
5.8.6 The development will be water-sensitive and climate-resilient throughout, with an innovative approach to future foul and potable water management. The large quantum of open and accessible green space to be delivered on site will aid this, addressing local green infrastructure deficiencies and providing a significant Biodiversity Net Gain.
5.8.7 Finally, and importantly, the development can facilitate improvements, including infrastructure improvements, to relieve congestion and conflicts where the London-Cambridge railway line crosses the A10.
5.8.8 It is well understood that this bottleneck has severe local impacts that detract from the quality of life of local people, as well as having wider social, economic and environmental impacts for the wider region.
5.8.9 Development of the Site creates unparalleled opportunity for Axis to work with the local community and other stakeholders, including Network Rail, Cambridge County Council, the forthcoming Development Corporation, and others to address this long-standing issue.
5.8.10 In this way, the vision for Land at Foxton supports significant growth and high-quality placemaking. The site is uniquely positioned to help deliver the Government’s ambition for sustainable growth in Greater Cambridge and providing a new community in a highly accessible location, outside the Green Belt, that will contribute directly to national and regional objectives while benefitting the local environment and community.
6. Housing Delivery in Cambridge
6.1.1 This Section assesses GCSP’s approach to housing delivery in the Draft Plan.
6.2 Housing Requirement
6.2.1 The Draft Plan identifies a Local Housing Need (LHN) based on the Government’s standard method of 2,289 dwellings per annum (dpa), equating to 48,069 homes required over the plan period (Draft Policy S/JH).
6.2.2 The Draft Plan sets out how these numbers will be met in Draft Policy S/DS. This is restated in Table Two below.
Table 2 – Total Housing Supply to Meet Identified Housing Need for 2024-2045
Homes to be delivered Homes 2024-2045
Current Supply 38,378
New Sites 13,654
Total supply 52,032
Headroom provided by total supply in relation to housing need 3,963 (8.2%)

6.2.3 The Draft Plan does, therefore, increase the housing target beyond the base LHN by providing a total supply of 52,032 homes. This 8.2% uplift is supported in principle. However, we would urge GCSP to consider that there is potential for additional growth within Greater Cambridge, as per the previously submitted Regulation 18 representations.
6.2.4 A housing strategy should not be considered effective simply because its total supply equals or marginally exceeds the numerical requirement across the plan period. The LHN should be a minimum requirement. In Greater Cambridgeshire, the economic drivers mean that the ambition must be to maximise housing delivery to support good economic growth in a sustainable way. The Local Plan should seek to deliver more housing to exceed calculated LHN in a wider geographical spread than is currently proposed. Currently, housing delivery is focused in the north of Cambridge, which creates an unsustainable imbalance. Furthermore, what matters is whether the homes are likely to be delivered when required and whether the strategy contains sufficient alternative supply if identified sites are delayed, reduced in capacity or affected by infrastructure constraints.
6.2.5 On this basis, there are several key indicators suggesting that a higher housing requirement would be justified in this case, namely:
 To adequately respond to and support Greater Cambridge’s economic growth potential and meet an unmet need for market and affordable housing;
 To provide sufficient flexibility to manage delivery risk, reducing the current reliance on a number of large and complex strategic new settlements; and
 To make effective use of opportunities in sustainable, well-connected locations, particularly in the south and south west.
6.3 Economic Growth Opportunities
6.3.1 The Draft Plan identifies a need to provide 73,300 additional jobs to support the Greater Cambridge’s knowledge intensive sectors and provide a diverse range of local jobs. GCSP have taken a central forecast from the Greater Cambridge Employment and Housing Evidence Update 2025 (EHEU) to underpin the employment figures in the Draft Plan. This assumes growth of around 3,500 additional jobs per annum or more through to 2045.
6.3.2 However, the EHEU identified that a higher growth forecast was likely, placing greater weight on rapid growth in the recent past, particularly in key sectors. This will be reinforced by the Government’s mandate for growth in the region.
6.3.3 On this basis, there is likely to be demand for more jobs than currently planned for. This is not reflected in the Draft Plan, but is nonetheless a realistic scenario. Given the ambitions of the Government and the Cambridge Growth Company, and the significant investment (£400 million of Government funding announced 23 October 2025) into Cambridge to support its future growth, there is no doubt that there will be additional growth.
6.3.4 The EHEU concludes that the Government’s Standard Method would support the forecast for future jobs. However, it is evident that the Draft Plan has not catered for the high growth scenario that is more likely to take place.
6.3.5 Additional growth to support the ambitions of the Government and Cambridge Growth Company should be incorporated into the Draft Plan. The Plan should identify a higher housing requirement and allocate additional deliverable and developable sites, including Land at Foxton, to provide greater certainty to housing delivery throughout the plan period.
6.4 Reliance on New Settlement Sites
6.4.1 The Draft Plan substantially relies on a limited number of large, strategic scale sites to meet Greater Cambridge’s housing requirement. While strategic development will be necessary on some scale to support Cambridge’s future growth, the concentration of housing delivery included in the Draft Plan within complex, long-term schemes creates a significant risk to the effectiveness and resilience of the Plan’s development strategy.
6.4.2 The Draft Plan caters for housing distribution of the following nature (Figure 9 of Draft Plan):
 11% in the Cambridge Urban Area (including windfalls);
 30% on the Edge of Cambridge;
 44% in new settlements; and
 15% in the Rural Area (including windfalls).
6.4.3 Large new settlements can deliver substantial numbers of homes and important supporting infrastructure, but delivery commonly depends upon the timely resolution of complex matters. A reliance of 44% housing delivery in new settlements is heavily weighted and requires the resolution of strategic scale infrastructure alongside.
6.4.4 Consequently, even relatively modest delays affecting one or more major allocations could have a disproportionate effect on the overall housing trajectory. This is a precarious strategy that will fail to deliver timely housing delivery.
6.4.5 Capacity and delivery expectations associated with strategic sites can change materially as technical evidence and infrastructure requirements are refined. It would therefore be inappropriate for the Plan to assume that every strategic allocation will deliver precisely in accordance with its stated capacity and anticipated trajectory over a 21-year plan period.
6.4.6 There must also be consideration given to the timing of housing trajectory delivery, rather than simply total quantity. The trajectory shown in the Draft Plan relies upon peaks in delivery, while delivery is expected to fall below the annual housing need in several years. Indeed, the trajectory highlights there to be no substantial delivery from new allocations prior to 2032/33. This demonstrates the underlying concern that the Plan’s ability to meet its requirement depends upon a limited number of strategic sites achieving substantial and sustained rates of delivery within particular periods (2032/33 onwards). This is a precarious model for housing delivery that does not guarantee deliverability over the plan period, rendering the Draft Plan ineffective.
6.4.7 The identification of sufficient housing land does not, in itself, establish that the Draft Plan will be effective. A sound strategy must demonstrate that homes can be delivered consistently and at the point at which they are needed. It should also provide sufficient flexibility to respond to delays, changes in infrastructure programmes, reduced site capacities, slower market absorption and other unforeseen circumstances. Where the requirement is treated as a minimum target, but the supply is heavily concentrated within a small number of complex locations, there is limited scope to compensate for under-delivery.
6.4.8 The Lichfields Start to Finish research document (February 2025), identifies that on average it takes 6.6 years from validation of the first planning application to the first dwelling being completed on scheme of 2,000 or more dwellings.
6.4.9 Table Three below shows the delivery of new settlements during the emerging Plan period, as described in the Draft Plan. Four of the new settlements over 2,000 units are yet to receive planning permission. It is our understanding that three of these (Cambourne North, Cambridge East and Grange Farm) are yet to have formal planning applications submitted. This totals 9,050 units (17% of the total supply).
6.4.10 If we assume that the majority of applications do not come forward until after the Draft Plan is adopted (assuming adoption in its current form), then the earliest these applications are likely to be submitted is the 2028/29 year. Taking the Lichfield’s analysis into account, this would mean most new settlement sites will not deliver first homes until 2034/35 – 2035/36.
6.4.11 This assumption is also made on the basis that the relevant sites are available and deliverable at the earliest opportunity. All these sites have significant infrastructure requirements which are only likely to further restrict and delay delivery.
6.4.12 There are, therefore, significant question marks about the ability of the Draft Plan to meet the overall housing target in a timely manner. Our expectation is that if the Draft Plan were to be adopted in its current form, then the GCSP would quickly fall behind its housing requirement targets both in terms of Five-Year Housing Land Supply (5YHLS) and Housing Delivery Test (HDT).
6.4.13 Indeed, several of the committed new settlement sites have fallen behind in their delivery. It would be reasonable to include a circa 10-20% lapse rate against all planning permissions that have not started to account for a reasonable assumption of delay, especially in the current economic climate. Applying a 10% lapse rate to the 18,219 committed homes would reduce the supply by 1,822 within the plan period. This is 80% of the annual LHN and 46% of the headroom allowed for in the Draft Plan. Depending on the timing of this impact, this could further expose the GCSP’s 5YHLS position or HDT score and undermines the entire housing trajectory.
Table 3 – Delivery of New Settlements During Emerging Plan Period
Settlement Number of Homes to be delivered in Plan Period Total Number of Dwellings Extant Permission Percentage of Homes Delivered in Plan Period
Bourn Airfield 3,500 3,500 Yes 100%
Waterbeach New town 5,721 10,975 Yes 52%
Northstowe 6,382 10,180 Yes 63%
Eddington (Phase 1) 2,616 5,500 Yes 48%
TOTAL 18,219
Cambourne North 2,550 13,000 No 20%
Cambridge East 3,950 8,000 No 49%
Grange Farm 2,550 4,500 No 57%
Eddington (Phase 2) 2,500 5,500 No 45%
TOTAL 11,550

6.4.14 The GCSP’s housing trajectory is also reliant on the new settlements of 2,000+ dwellings each delivering 300 units per annum (with an initial five years and final five years at reduced rates of 50, 100, 150, 200 and 250 dwellings). This level of delivery far exceeds the highest average annual build-out rate for schemes of 2,000+ dwellings found in the Lichfields Start to Finish report of 100-188 dpa. This further exacerbates the precarious and problematic approach to housing trajectory included in the Draft Plan.
6.4.15 In its current form, the Draft Plan fails to provide a strategy which would meet the area’s objectively assessed needs within the plan period. The strategy is not deliverable and so the Draft Plan fails to be effective or positively prepared in this way.
6.4.16 It is evident that the Plan would benefit from a more diverse portfolio of allocated sites, comprising a range of geographies, scales, markets and delivery models. This would reduce dependence on individual strategic locations and enable housing delivery to be maintained if one or more major allocations were delayed. Such diversification would not undermine the role of the Plan’s existing strategic sites. Rather, it would improve the overall resilience of the strategy and increase confidence that the minimum housing requirement can be met in a full and timely manner.
6.4.17 Land at Foxton is particularly well suited to fulfilling this role. The Site has previously been identified through the Housing and Employment Land Availability Assessment as having capacity for approximately 1,500 homes and employment floorspace. It adjoins a well-connected railway station, lies outside the Cambridge Green Belt and is capable of delivering a comprehensively planned, residential-led mixed-use community supported by new infrastructure, services, employment opportunities and extensive green infrastructure.
6.4.18 The Site would also introduce an additional source of supply within close proximity to Cambridge and the CBC, the benefits of which have already been set out in these representations.
6.4.19 Importantly, Land at Foxton should not be viewed simply as another large strategic site replicating the risks inherent elsewhere in the strategy. Its scale and location differentiate it and make it truly available and deliverable without the need for lengthy processes such as Green Belt release or transport infrastructure required to serve new settlements. The Site would complement the other allocations and provide greater certainty to GCSP’s housing delivery.
6.4.20 Furthermore, it is uniquely located to provide the opportunity to facilitate improvements to relieve the congestion and conflicts at the Foxton level crossing.
6.4.21 The omission of the Site is a missed opportunity by GCSP to introduce greater flexibility into the housing strategy and address a long-standing bottleneck for the benefit of the local community and the wider region. We urge them to reconsider this as part of this Local Plan Review.
6.5 Spatial Strategy
6.5.1 In identifying its preferred strategy, GCSP considered a range of potential sources of housing supply. Chapter Four of the Sustainability Appraisal (SA) sets out the various strategic spatial options explored by GCSP in preparing the Draft Plan. Since 2019, there has been a cumulative total of 24 different iterations of spatial options.
6.5.2 Despite some exploration of growth opportunities around transport nodes, there is no appreciation or consideration for the sustainability of sites along key southern transport routes. Indeed, the SA references the latest strategic spatial options as having ‘limited development distributed across Rural Centres, Minor Rural Centres, and Group Villages with very good Public Transport Access’ in both the southern cluster and the rest of the rural area villages.
6.5.3 The Plan’s own evidence, therefore, recognises that public transport accessibility and proximity to employment are relevant considerations in determining the most sustainable distribution of growth. This accords with paragraph 77 of the 2024 NPPF and Policy S5 of the 2026 NPPF regarding siting development in sustainable and accessible locations.
6.5.4 Despite this, there is a simple dismissal of sites for consideration along well-connected and strategically located routes, with connections to nationally important economic nodes such as Cambridge, South Cambridge, London, and the wider Oxford-Cambridge arc. The spatial strategy does not make effective use of the development opportunities available at the most sustainable rural transport locations.
6.5.5 The spatial strategy directs a substantial proportion of growth towards the Cambridge urban area and the edge of Cambridge in the north. These locations are proposed to play an important role in housing delivery, but as identified above, this is not guaranteed. The Plan does not establish a sufficiently balanced distribution of growth across Greater Cambridge. This is evident in Figure 1 below.
Figure 1 – Illustrative Map Showing Locations of New Housing Development from 2024 to 2045 (Draft Plan Figure 6)

6.5.6 The Draft Plan’s spatial strategy creates several concerns:
 It increases dependence on a narrow range of complex strategic locations and related infrastructure in those areas;
 It provides insufficient flexibility if strategic infrastructure is delayed;
 It limits opportunities to diversify housing delivery across different markets;
 It does not make full use of existing railway stations and transport corridors; and
 It is not aligned with comprehensively planned employment growth.
6.5.7 The Draft Plan does not make sufficiently effective use of land in highly accessible locations. Figure 2 below makes this point clear, in that when compared with Figure 1 there appears a clear disparity between the delivery of major transport projects and corresponding housing delivery in the south west of Cambridge.
Figure 2 – Map of Existing and Proposed Major Transport Projects (Draft Plan Figure 10)

6.5.8 A more positive strategy would recognise the role that rail-connected development can play in reducing reliance on the private car, supporting access to employment and aligning housing with infrastructure.
6.5.9 These are compelling reasons to supplement the Draft Plan with a wider portfolio of sustainable sites offering different locations, scales, markets and delivery characteristics that better align with strategic infrastructure delivery. This would better align the Draft Plan with paragraph 77 of the 2024 NPPF and reflect the ambitions of Policy S5 of the 2026 NPPF.
6.5.10 On this basis, to make the Draft Plan sound and to make it consistent with national policy, the GCSP should broaden the portfolio of allocations to recognise the importance of sites close to railway stations, and to include a more balanced mix of locations, scales and delivery models to better align the spatial strategy with logical locations for growth.
6.5.11 If the Draft Plan was to be adopted in its current form, it would fail the tests of soundness as a plan that is:
 Not positively prepared – unable to meet the area’s objectively assessed needs;
 Unjustified – with an inappropriate housing strategy which does not consider reasonable alternatives based on robust evidence;
 Ineffective – as the housing trajectory is undeliverable within the plan period; and
 Inconsistent with national policy – without consideration for siting new development in sustainable locations that are well located, currently supported by the necessary infrastructure and facilities, and include a genuine choice of transport modes.
6.5.12 Draft Policy S/DS sets out that strategy for the plan period to 2045 and beyond for the location of jobs and homes. Strategic scale allocations are located in the first instance within the Cambridge urban area, on the edge of Cambridge, at new settlements and in rural southern clusters.
6.5.13 Axis has significant concerns with the soundness of the approach taken to creating a development strategy in the Draft Plan. This Policy is addressed in full in the preceding section of these representations.

Draft Policy S/SH should be amended to better reflect the sustainability, accessibility and growth potential of rail-connected settlements. In particular, the policy should:
- Adjust the distribution of development within the settlement hierarchy to place greater emphasis on site deliverability and sustainability, rather than existing settlement classifications alone.
- Recognise that settlement hierarchy designations should inform, rather than dictate, the location of future growth.
- Give greater weight to settlements with direct rail access and strong public transport connectivity, such as Foxton.
- Explicitly acknowledge the role of well-connected railway stations in supporting sustainable, transit-oriented development.
- Reassess the treatment of Foxton within the hierarchy to reflect its strategic location on the Cambridge rail corridor and its ability to accommodate growth.
- Amend the settlement strategy and site allocation process to distinguish rail-connected settlements from other villages within the same tier.
- Update Figure 11 and supporting evidence to identify well-connected railway stations and demonstrate how the spatial strategy aligns with sustainable transport infrastructure.
- Ensure the policy is consistent with Paragraph 77 of the 2024 NPPF and the approach in the 2026 NPPF regarding development around well-connected stations.

These amendments would create a more flexible and sustainable settlement hierarchy, make better use of existing transport infrastructure, and reduce the risk of the policy being found unsound at examination.

6.6.2 The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy S/SH in particular. On this basis, please refer to the attached representations for a comprehensive response.
6.6.3 Draft Policy S/SH Settlement Hierarchy sets out that residential development and redevelopment will be permitted within the settlement extents as defined on the Policies Map, provided that adequate services, facilities and infrastructure are available or can be made available as a result of the development. The approach to the Settlement Hierarchy is broadly supported. However the balance of development within settlement types should be adjusted to reflect the deliverability of sites.
6.6.4 The Draft Plan identifies Foxton as a Group Village within the settlement hierarchy, with residential development up to an indicative maximum scheme of 8 dwellings.
6.6.5 Throughout the Draft Plan, Foxton is treated primarily by reference to its existing designation as a Group Village, rather than its functional role as a rail-connected location within the southern Cambridge growth corridor. The approach is unduly restrictive and fails to recognise that settlement hierarchies should inform, rather than determine, the distribution of development. A settlement’s present size and range of services reflect historic patterns of growth. They do not necessarily provide an appropriate basis for deciding where comprehensively planned new development should occur over a plan period, particularly where development itself is capable of delivering new services, facilities and strategic infrastructure.
6.6.6 As highlighted in the previously submitted Regulation 18 representations, the assessment of Foxton has failed to adequately recognise the strategic advantages arising from its direct access to a mainline railway station and its established rail connection into Cambridge. The role of rail accessibility has been consistently overlooked or significantly undervalued throughout the Site assessment process. For this reason, the Draft Plan directs very limited growth towards settlements benefitting from existing railway infrastructure, representing a significant missed opportunity to maximise the use of sustainable transport assets that are already in place.
6.6.7 This conflicts with the paragraph 77 of the 2024 NPPF and the Government’s ambitions set out in the 2026 NPPF regarding the delivery of housing adjacent to well-connected stations. The 2026 NPPF proposes minimum development densities of 35 dwellings per hectare around well-connected stations and 45 dwellings per hectare around those with higher connectivity. This reflects a clear objective to maximise opportunities for sustainable, transit-oriented development.
6.6.8 The 2024 NPPF recognises that planning for a large number of new homes can often best be achieved through supporting larger scale development in well located areas, supported by necessary infrastructure and facilities that provide a genuine choice of transport modes. In the Settlement Hierarchy, greater weight should therefore be afforded to settlements like Foxton, containing railway stations.
6.6.9 Settlements such as Foxton, which are located on strategic public transport corridors and benefit from direct rail access, possess a significantly greater capacity to accommodate sustainable growth than other villages within the same tier of the hierarchy. This distinction should be explicitly recognised through both the settlement strategy and site allocation process. Figure 11 should include reference to locations of well-connected railway stations in and around Cambridge, to demonstrate that the proposed spatial strategy is sound in this respect.
6.6.10 Without a material change in the approach to the settlement hierarchy in the Draft Plan, GCSP risk it being found unsound at Examination on the basis of this inconsistency with national policy.

Draft Policy S/DE should be amended to ensure it is consistent with national policy and allows for sustainable growth beyond defined development extents. In particular, the policy should:
- Introduce greater flexibility to support development in sustainable rural locations outside settlement boundaries.
- Recognise opportunities for villages to grow and thrive where development would support local services and community vitality, consistent with Paragraph 83 of the 2024 NPPF.
- Allow positively planned growth at sustainable locations that are well connected to public transport infrastructure.
- Include specific support for residential and mixed-use development adjacent to well-connected railway stations where proposals are physically related to an existing settlement.
- Ensure consistency with the ambitions Policy S5 of the 2026 NPPF, which supports certain forms of development outside settlements near well-connected stations.
- Amend the restrictive approach to defined development extents to avoid conflict with future national policy and reduce the risk of the policy being afforded limited weight in decision-making.

These amendments would make the policy more positively prepared, effective, and aligned with both current and emerging national planning policy.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy S/DE in particular. On this basis, please refer to the attached representations for a fulsome response.
6.7.2 Draft Policy S/DE states outside defined development extents, development will not be permitted except for allocations within made neighbourhood plans, rural exception sites meeting local need for affordable housing, or where development is supported by other policies in the Plan. The Site is located outside the defined development extent and is not allocated within the neighbourhood plan.
6.7.3 Draft Policy S/DE is not positively prepared or consistent with national policy. Paragraph 83 of the 2024 NPPF states that ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services’. Draft Policy S/DE does not support the opportunity for Foxton to grow and thrive. It has been established that the Site is a sustainable location for growth, however Draft Policy S/DE is restrictive in that it would not allow Foxton to grow beyond its current development extents. This is not consistent with 2024 NPPF.
6.7.4 Furthermore, Draft Policy S/DE will conflict with Policy S5 of the 2026 NPPF. Policy S5 addresses developments outside settlements and confirms that certain forms of development should be approved outside settlements. This includes residential and mixed used development which would be within reasonable walking distance of a well-connected station and be physically well related to the station or the settlement within which the station is located. An assessment of the Site against these criteria is provided in the preceding sections of these representations.
6.7.5 Therefore, on adoption of the Draft Plan, Draft Policy S/DE will immediately conflict with Policy S5 of the 2026 NPPF. Annex A of the 2026 NPPF confirms that policies examined and adopted under the 2024 NPPF which are materially inconsistent with national decision-making policies in the 2026 NPPF should be given very limited weight. Amending Draft Policy S/DE now will avoid this.

Draft Policy CC/WE should be amended to ensure that water efficiency requirements are evidence-based, deliverable and sufficiently flexible. In particular, the policy should:
- Remove or revise the requirement to comply automatically with undefined future water efficiency standards that may be introduced after adoption of the Local Plan.
- Ensure any future standards are subject to proper evidence gathering, needs assessment and testing through the plan-making process before being applied.
- Introduce greater flexibility so that developments are not required to meet unviable or unachievable standards that have not been objectively assessed.
- Retain the current water efficiency objectives while providing mechanisms to consider deliverability and viability.
- Ensure water efficiency requirements do not adversely affect housing delivery or undermine the implementation of otherwise sustainable development.

These amendments would help ensure the policy is justified, effective, positively prepared and capable of supporting housing delivery while continuing to promote water conservation.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy CC/WE in particular. On this basis, please refer to the attached representations for a comprehensive response.

Draft Policy CC/WE requires new development to demonstrate highly water efficient design to minimise consumption of water and protect water requirements. Axis supports this ambition, in the context of wider water availability concerns within the region. Land at Foxton will target the prescribed standards, which states 80 litres-per-person-per-day usage. This will be met through efficient sanitaryware, appliances and fittings together with some form of water re-use or recycling.

The Flood Risk and Drainage Note at Appendix D sets out the suitability of the Site in regard to water concerns in the region and endorses Axis’ support for this Draft Policy.

Part 5 of the Draft Policy requires accordance with non-descript future standards where, at any point in the future, they are ‘more stringent or at significant variance with this policy’. This is not an appropriate approach for the Draft Plan to take. The Draft Plan should undertake a needs-tested assessment to define policy. The policy wording requires compliance with future policy or legislation that has not been tested or assessed. The Draft Policy is therefore unjustified, ineffective and not positively prepared.

Draft Policy CC/WE should be sufficiently flexible with regards future standards, to ensure that unviable or unachievable standards that are not objectively assessed via the Local Plan process are not enforced on developments. This has potential implications on housing delivery, which, as already demonstrated in these representations, there are existing concerns regarding.

Draft Policy CC/IW should be amended to provide stronger and more explicit support for developments that deliver improvements to integrated water management infrastructure. In particular, the policy should:
- Explicitly support developments that provide upgrades to water infrastructure, including both fresh water and wastewater infrastructure.
- Give significant weight to proposals that contribute to addressing local and regional water stress, reflecting Greater Cambridge’s status as an area of serious water stress.
- Recognise and support infrastructure improvements delivered both on-site and off-site where wider benefits can be demonstrated.
- Encourage and support investment in strategic water infrastructure upgrades that serve the development and the wider area.
- Amend the policy wording to align with Chapter 10 of the 2024 NPPF and the ambitions of Policy W4 of the 2026 NPPF by granting substantial weight to the benefits of new and improved water infrastructure.
- Ensure the policy is positively prepared, justified, effective and capable of meeting the area's future water management needs.

These amendments would strengthen the role of water infrastructure delivery within the policy framework and better support sustainable growth across Greater Cambridge.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy CC/IW in particular. On this basis, please refer to the attached representations for a comprehensive response.

Draft Policy CC/IW requires an integrated approach to water management. It is relevant that the Sites abuts the Foxton Wastewater Recycling Centre (FWRC). This means that there could be an opportunity to expand the FWRC, if it would help wider fresh and foul water issues in south west Cambridge. Axis are committed to engaging with Anglian Water (AW) to understand AW’s investment plans for the FWRC going forward. In its current form, the Draft Policy does not provide explicit support or substantial weight to development that improves water infrastructure. The Draft Plan includes the notion that Greater Cambridge is one of the driest areas in the UK, and Cambridge Water’s supply zone is classified as an area of ‘serious water stress’ by the Environment Agency. On this basis, significant weight should be afforded to proposals that provide opportunities to improve integrated water management infrastructure, whether on-site or off-site. The Policy should support development that provides local or even regional improvements to water infrastructure also, ensuring that developments with plans to aid regional water stress are afforded the correct level of support.

Draft Policy CC/IW as it currently stands is not positively prepared in that is does not provide a strategy that seeks to meet the area’s objectively assessed needs. A change to the wording to explicitly support development that improves integrated water management infrastructure, both for the development and more widely, is required. This would ensure the Draft Plan is positively prepared, justified, effective and consistent with Chapter 10 of the NPPF and Policy W4 specifically, in planning for future upgrades and granting substantial weight to the benefits of new water infrastructure.

Draft Policy BG/BG should be amended to ensure it is consistent with national policy, evidence-based and deliverable. In particular, the policy should:
- Reduce the minimum Biodiversity Net Gain (BNG) requirement from 20% to 10% to align with the statutory requirement, Planning Practice Guidance (PPG) and national policy.
- Provide robust evidence and justification if a higher-than-statutory BNG requirement is to be retained.
- Test the deliverability and viability implications of any enhanced BNG requirement across proposed site allocations.
- Ensure BNG requirements do not unnecessarily reduce developable land or compromise the efficient use of land.
- Consider the cumulative impact of BNG alongside other policy requirements, including affordable housing, open space and infrastructure contributions.
- Amend the policy to avoid adversely affecting housing delivery and to ensure the Local Plan remains positively prepared, justified, effective and consistent with national policy.

These changes are intended to improve policy soundness while still securing meaningful biodiversity enhancements.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy BG/BG in particular. On this basis, please refer to the attached representations for a fulsome response.

Draft policy BG/BG sets out that major development must provide a minimum of 20% biodiversity net gain (BNG) to be provided on-site where this is feasible and effective, or off-site where onsite options for BNG have been evidenced to be exhausted as agreed with the Local Planning Authority (LPA). The proposed 20% BNG exceeds statutory gain requirements. GCSP’s approach is underpinned by the recognised need to enhance biodiversity across Cambridgeshire, which currently has one of the lowest proportions of land managed for nature in England. This need is reflected in the Cambridgeshire Doubling Nature Vision and is reinforced by the relatively low coverage of designated sites and priority habitats within Greater Cambridge compared to other areas of England.

The 2024 Planning Practice Guidance (PPG) on Biodiversity Net Gain states that Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. This is reflected in Policy N1 of the 2026 NPPF. The requirement for 20% BNG has not been set for specific site allocations, and this lack of mandate means that these sites fall back on the Draft Plan requirement of 20%. There is no evidence that 20% BNG is deliverable or achievable on any sites.

Draft Policy BG/BG is therefore inconsistent with the PPG and should reflect the prevailing national policy position of a 10% BNG requirement. The Draft Policy is also not positively prepared, justified or effective in that it is likely to impact on housing delivery within the plan period. The proposed site allocations are untested in this respect, and a 20% BNG requirement effectively doubles the amount of land required for mitigation planting where an on-site solution is proposed. This conflicts with the best use of land principles contained within the NPPF and has implications on the amount of land within these allocations available for development. There are already significant concerns with the delivery of sufficient housing within the plan period, as set out in earlier sections of these representations. The Draft Policy as currently drafted will only exacerbate this.

Draft Policy I/MH should be amended to strengthen support for mobility hubs and provide greater clarity regarding their delivery. In particular, the policy should:
- Give greater policy weight to developments that deliver mobility hubs in sustainable and well-connected locations.
- Identify more appropriate locations for mobility hubs within the policy or supporting text, including Foxton as a priority location.
- Explicitly support the delivery of a mobility hub at Foxton, recognising its potential to improve integration between rail, bus, car and active travel modes.
- Recognise the wider benefits of mobility hubs in promoting modal shift, improving accessibility and supporting sustainable development patterns.
- Include additional guidance on how mobility hubs should integrate with the requirements of Draft Policy WS/NC.
- Introduce clearer provisions regarding viability testing and needs testing to ensure mobility hub requirements are proportionate and deliverable.

These amendments would improve the policy’s effectiveness, better align it with national policy objectives on sustainable transport, and provide stronger support for strategically located mobility hub proposals.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy I/MH in particular. On this basis, please refer to the attached representations for a comprehensive response.

Draft Policy I/MH states that proposals for new mobility hubs in appropriate locations will be supported. The approach to mobility hub facilities is supported and recognised for its contribution in encouraging modal shift and the use of more sustainable transport modes. The supporting text adds that these facilities will be supported subject to necessary impact assessments and a business case to demonstrate the commercial viability.

In its current form, the Draft Policy does not provide substantial weight to development that provide mobility hubs in appropriate locations. Without this, the Draft Policy lacks soundness. The 2024 NPPF is clear in its directive that development should be located in sustainable locations, where there is a genuine choice of transport modes. The benefits of mobility hub facilities in sustainable locations should therefore be afforded the requisite weight. It would be helpful if the Draft Policy identified some appropriate locations, such as Foxton, where there has been a long-term aspiration for the provision of a mobility hub.

Foxton station is located on the edge of the village. The introduction of a mobility hub would bring the station into the heart of the community and promote the use of public transport through the provision of amenities, employment uses, and local facilities. The proposed multi-modal mobility hub would be linked to accessibility improvements to the train station and A10 interface. These aspirations for a high-quality interchange between car, bus, rail and active travel infrastructure would have a positive impact in a sustainable location. The Draft Policy should, therefore, explicitly support the delivery of a mobility hub at Foxton.

Further wording should be incorporated to better explain how these requirements could integrate with the delivery of draft Policy I/MH, with detail added on potential viability testing and needs testing.

Draft Policy WS/NC should be amended to ensure it recognises and positively supports developments that deliver infrastructure, services and facilities beyond those required solely to mitigate the impacts of the development. In particular, the policy should:
- Give explicit support and substantial weight to developments that provide wider community benefits and strategic infrastructure serving existing as well as new residents.
- Recognise the value of transformative developments that deliver facilities and services at a broader settlement or area-wide scale.
- Ensure requirements for indoor and outdoor sports provision are evidence-based, proportionate and linked to demonstrated need.
- Include a needs-testing approach so that contributions are only sought where justified by local demand.
- Afford greater policy weight to developments that deliver appropriate infrastructure and community facilities beyond the immediate requirements of the scheme.

These amendments would improve the policy’s effectiveness, proportionality and overall soundness.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy WS/NC in particular. On this basis, please refer to the attached representations for a fulsome response.

Draft Policy WS/NC requires new developments to deliver services and facilities necessary to mitigate the impact of the development on existing local facilities. This supporting information states new major developments will need to include a wide range of services and facilities to establish successful communities.

In its current form, Draft Policy WS/NC does not provide explicit support or substantial weight to development that provides services that do not only mitigate the impact of the development but add further value beyond this. Without this, the Draft Policy lacks soundness. The Site at Foxton has the potential to be transformative for the area, introducing a range of facilities and services that are not only generated by the development but go beyond this remit and serve Foxton on a wider scale.

Draft Policy WS/NC also requires residential development to contribute towards both indoor and outdoor sports. All contributions should be site specific and means tested; there should not be a requirement to provide indoor sports where there is no demand or need.

The benefits of providing appropriate infrastructure and facilities, means tested and on a broader scale than the development itself, should therefore be afforded the requisite weight in policy terms. The Draft Policy must be amended in this way to ensure effective implementation and soundness.

Draft Policy BG/EO should be amended to provide greater clarity, flexibility and certainty regarding open space requirements. In particular, the policy should:
- Clarify how food growing spaces will be managed and maintained over the long term.
- Explain how open space requirements interact with Biodiversity Net Gain (BNG) and Urban Greening Factor (UGF) requirements, avoiding duplication and double counting.
- Recognise the long-term management and maintenance costs associated with large areas of open space and consider the implications for future residents.
- Incorporate viability and deliverability considerations when determining open space requirements.
- Include a definition of “Accessible Greenspace”, which is currently referenced but not provided in the glossary.
- Clarify whether play space and food growing space count towards the overall accessible open space requirement.
- Provide a clear methodology for calculating financial contributions where on-site provision is not possible.

These amendments would improve the policy’s effectiveness, transparency, viability and overall soundness.

The following text is taken from Chapter 4 of the Draft Representations attached to this submission. These representations are drafted on behalf of Axis Land Partnerships in relation to the site known as Land at Foxton. The representations should be read as a whole, as the Draft Local Plan is, to provide a comprehensive response to the Plan and Draft Policy BG/EO in particular. On this basis, please refer to the attached representations for a fulsome response.

Draft Policy BG/EO set out that new development must address the open space needs it generates though a mix of on-site provision and/or financial contributions for off-site open space provision, enhancement and/or management.

The Draft Policy requires all major developments that are predominantly residential led to provide accessible green space, play and youth space and food growing space. This policy is broadly supported in principle, but it must be further refined to ensure it meets the tests of soundness. For example, it is not clear how the growing space would be managed. Also, it is unclear how the provision of open space is compatible with BNG requirement and Urban Greening. It should also be recognised that long term maintenance of large areas of open space can burden future residents with unexpected service changes. There is no provision for scheme delivery or viability in this context either.

This Draft Policy is justified by a recognised under-provision of accessible greenspace in Greater Cambridge. This is particularly in relation to strategic-scale open spaces, that is district and sub-regional spaces of over 100 hectares. Also, the supporting text notes Accessible Greenspace is defined in the glossary, however, this definition is missing.

Finally, it should be clarified however whether the amount of play space and food growing space is included within the total amount of accessible open space.

Where these developments cannot be delivered on site a financial contribution will be secured. The flexibility of the wording of this policy is welcomed, but further details on how financial contributions will be calculated should be provided. The Draft Policy therefore requires further clarification and redrafting in order to ensure it meets the tests of soundness.