Greater Cambridge Local Plan: Proposed Submission

Draft Policy I/SI should be amended to provide a more proportionate and evidence-based approach to safeguarding rail freight facilities and sidings at Foxton. In particular, the policy should:
- Include clearer guidance on the type and scope of evidence required to demonstrate that development would not prejudice existing or future rail freight and interchange operations.
- Adopt more flexible wording that allows the compatibility of development proposals to be assessed on their merits.
- Review and justify the necessity of the safeguarding requirements in light of evidence from comparable developments, such as the former Cemex Cement Works site at Barrington, where residential development has proceeded without adversely affecting nearby rail infrastructure.
- Ensure the policy is sufficiently justified and effective to meet the tests of soundness.

These changes would improve clarity, reduce uncertainty for applicants and help ensure the policy is evidence-led and proportionate.

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/SI in particular. On this basis, please refer to the attached representations for a fulsome response..

Draft Policy I/SI seeks to safeguard existing rail freight facilities and sidings at Foxton for rail freight and interchange facilities. The aspirations of the Draft Policy are understood, but there should be a more nuanced approach to the policy wording. Further guidance on what evidence will need to be submitted to justify that future development would not prejudice the rail freight or interchange facility should be included.

Indeed, the Redrow scheme that has been permitted and subsequently developed at the Former Cemex Cement Works in Barrington indicates that the development of housing close to the existing line will not prejudice its use. The necessity of the Draft Policy is therefore questioned in this context. In its current form, the Draft Policy does not support the aspirations of a sound Plan.

Draft Policy H/SH should be amended to improve its effectiveness, flexibility and consistency with the evidence base. In particular, the policy should:
- Apply specialist housing requirements consistently across both allocated and unallocated strategic sites, rather than only unallocated sites.
- Broaden its focus beyond older persons’ and disabled accommodation to recognise other identified specialist housing needs, including housing that supports the Cambridge Biomedical Campus workforce and wider economic growth.
- Introduce a needs-based approach, allowing specialist housing requirements to be tailored to demonstrated local demand.
- Include viability testing and review mechanisms to ensure specialist housing requirements do not undermine scheme deliverability when considered alongside other planning obligations.
- Provide greater flexibility in how specialist housing is delivered on a site-by-site basis.

These amendments would help ensure the policy is positively prepared, justified, effective and capable of meeting objectively assessed specialist housing needs.

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 H/SH in particular. On this basis, please refer to the attached representations for a fulsome response.

Draft Policy H/SH states that unallocated strategic sites of 1,000 dwellings or more will be expected to provide at least 10% of homes as specialist housing. This policy focuses on the need of older people and disabled people, although it is recognised that other specialist housing will be supported if there is appropriate evidence of need. The Draft Policy states proposals will be expected to have regard to the evidence base supporting the Local Plan which considers the needs of a wide range of groups.

This Draft Policy is not prepared in line with the tests of soundness set out in the NPPF. There are no allocation policies requiring a defined proportion of specialist housing, extra care housing, retirement housing, care homes, or older persons' accommodation. The Draft Policy’s applicability to unallocated sites only is unjustified and renders the policy ineffective, in that it will fail to deliver specialist housing across the majority of its housing stock (ie allocated sites). The Policy will therefore fail to meet the meet the area’s objectively assessed needs effectively.

The Draft Policy also has an overly focused approach to delivering for the needs of older and disabled persons. While this is understood, there is an evidenced unmet need for specialist housing to support CBC and its growth aspirations. The demand for this type of housing is addressed in earlier sections of these representations and at Appendix B.

The Draft Policy also does not provide flexibility for the required provision to be tested and the requirement, on top of other planning obligations, could result in schemes being made unviable. There should be an opportunity for the provision of specialist housing to be needs tested on a site-by-site basis and so this policy is not supported at this stage, given the requirement is not fully justified.

Without changes made to the Draft Policy as set out above, it will remain unsound.

Draft Policy H/AH should be amended to introduce greater flexibility in the delivery of affordable housing and to ensure requirements do not undermine scheme viability or housing delivery. In particular, the policy should:
- Allow affordable housing requirements to be subject to viability review where evidence demonstrates that the 40% target cannot be delivered alongside other policy obligations.
- Include flexibility in the timing and phasing of affordable housing provision on large or phased developments.
- Recognise that a lower, viable affordable housing percentage may deliver more affordable homes in practice than an unachievable target that delays or prevents development.
- Ensure affordable housing requirements are balanced alongside other burdens such as Biodiversity Net Gain, open space, infrastructure and planning obligations.
- Include mechanisms for reviewing requirements where circumstances change during the build-out of long-term developments.

These changes would improve the policy's effectiveness, support housing delivery, and help ensure the Local Plan meets its objectively assessed housing needs.

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 H/AH in particular. On this basis, please refer to the attached representations for a fulsome response.

Draft policy H/AH states that major housing development will provide at least 40% of the new homes on site as affordable housing. The policy requires that new affordable housing is phased proportionally within the build out of the development to enable proper integration.

The NPPF states development proposal should meet or exceed up-to-date development plan requirements for the proportion and mix of affordable housing tenures relevant to the location, including the minimum proportion of social housing. Whilst GCSP’s ambitious requirement for 40% affordable housing will challenge the viability of many schemes when considered alongside other policy requirements (BNG, open space etc). The Draft Policy does not include wording to enable flexibility in the way affordable housing is built out or reviewed. On a phased development unrealistic affordable housing requirements could affect a site’s deliverability. This will have implications for the GCSP in terms of overall housing delivery, not just affordable housing.

A lower affordable housing requirement that makes the delivery of schemes viable, will provide more affordable homes than a higher requirement that results in schemes not being delivered. This will ensure a Plan that meets the area’s objectively assessed needs.

Axis would support the addition of wording to provide greater flexibility on affordable housing provision and to ensure that developments can successfully meet the requirements of the development plan without unduly restricting delivery. The Draft Policy should be amended to reflect this.

Draft Policy BG/UGF should provide evidence to justify why residential development outside the Cambridge Defined Development Extent must achieve a higher Urban Greening Factor (UGF) score than development within it.

The Draft Policy should also clearly explain the relationship between UGF, Biodiversity Net Gain (BNG) and open space requirements, setting out how these requirements interact in practice and avoiding unnecessary double counting. These amendments would improve policy effectiveness, protect development viability, provide greater certainty to applicants and help ensure a deliverable housing supply throughout the plan period.

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/UGF in particular. On this basis, please refer to the attached representations for a comprehensive response.

Draft Policy BG/UGF states that major development must demonstrate how the development will achieve Urban Greening Factor (UGF) scores of at least 0.5 for predominantly residential development outside Cambridge Defined Development Extent, except where it can be demonstrated that more than 50% of the Site area equates to accessible greenspace.

This policy is broadly supported, and Axis welcomes the flexibility the policy provides in clarifying the requirement applies to the whole development rather than individual phases. However, no justification has been included to demonstrate why the UGF score for development outside of the defined development extent must exceed the requirements for developments within the defined development extent. This must be clarified to ensure a justified and effective policy.

It would be helpful if Draft Policy BG/UGF included an explanation as to how UGF relates, and is compatible with, BNG and open space requirements. Page 509 of the Draft Plan clarifies that UGF and BNG are separate requirements but there is inevitable interrelation between the two. This must be clarified in the Draft Plan to ensure a justified and effective policy and to ensure a deliverable supply of housing, so that development viability is not overly constrained as a result of unnecessary double counting.

Axis requests kindly that Land at Foxton is included in the Draft Plan as a suitable, available and deliverable site.

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.