Greater Cambridge Local Plan: Proposed Submission

Object

Representation ID: 214015

Received: 25/09/2026

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

This representation relates to Appendix D - Housing trajectory and five-year housing land supply calculation. It remains relevant that of the 52,032 homes identified in the dGCLP (Reg 19) for delivery over the plan period, more than 7,000 of these are windfalls. Of these, only 2,052 homes are on specific identified sites. Therefore, more than 5% of the dGCLP’s (Reg 19) housing requirement is future speculative, unidentified development. Whilst the principle of applying a windfall allowance is not disputed, such a significant portion of windfall supply leaves significant parts of the housing trajectory as unknowns. Consideration should be given to the potential of omissions sites, which could be strategically planned with accompanying policies, designed to meet the strategic goals of the plan that would facilitate a more joined-up approach to development for the 7,225 homes currently anticipated on unidentified windfall sites.

Object

Representation ID: 214048

Received: 25/09/2026

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

CEG LP has identified the flaws in the methodological approach to quantifying the relationship between need for jobs and homes. It does not take account of the latest projections. Its approach to HRRs is flawed and bakes in historic housing shortages in Cambridge City and South Cambridgeshire. Critically, it fails to recognise that an increase in households associated with extra economic activity and household growth will worsen affordability pressures, all things being equal, and there is no uplift for affordability in the methodology that would have any material impact on the ability of those groups – such as younger people and other concealed households – to better access homes at a price consistent with their incomes. Consequently, the dGCLP (Reg 19) is not currently sound because its evidence is flawed and likely underestimates the number of homes necessary to meet the housing needs associated with increased levels of economic activity and thus overcome barriers to investment necessary to achieve it, contrary to NPPF paras 61, 63 and 85 and 86 (d).

Object

Representation ID: 214049

Received: 25/09/2026

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

The dGCLP (Reg 19) is underpinned by an updated Sustainability Appraisal (July 2026), however this does not introduce any additional options for housing or employment growth quanta, instead ‘doubling down’ on the preferred approach underpinning the Policy S/JH.

On this basis, the dGCLP (Reg 19) is currently not sound because is it not justified (NPPF para 36b), insofar as the overall development strategy has effectively not considered any reasonable alternative growth quantum scenarios. This could be addressed by updating the SA to include alternative, higher, housing and job growth scenarios. This updating should be undertaken prior to the submission of the dGCLP for examination albeit after being subject to consultation.

Support

Representation ID: 214050

Received: 25/09/2026

Respondent: CEG Land Promotions Limited

Agent: Lichfields

CEG LP supports the expansion of the Biomedical Campus. Cambridge cluster companies successfully pitched for $2bn funding in 2025, which was across both the tech sector ($1.19bn) and life sciences ($896m), highlighting that both sectors are highly important to keeping Cambridge as a vibrant tech city. It is therefore indicative that Greater Cambridge has both a booming life sciences and tech sector. As an example, following the removal of Fulbourn Technology Park from the Green Belt in the South Cambridgeshire Local Plan 2018 it has flourished, as has TusPark at the Cambridge Science Park.

Object

Representation ID: 214058

Received: 25/09/2026

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

The HELAA is crude and heavy handed in its assessment and is not in all cases correctly applying its own methodology, it cannot be considered accurate nor robust. CEG LP consider that policies informed by this evidence-based document cannot be justified as per NPPF paragraph 36(b) as the strategy of the dGCLP (Reg 19) is not based on accurate, and therefore not proportionate, evidence. Furthermore, it means the HELAA is not in accordance with NPPF paragraph 32 which states local plan preparation should be underpinned by relevant and up to-date evidence. This cannot be the case when the evidence base itself is inaccurate.