Full text:
These representations are supported by the enclosed Note on Housing Need and Supply Matters. This
concludes that the proposed housing requirement of Policy S/DS is unsound because:
I.
II.
III.
It relies upon a windfall allowance of non-specific sites in years 1-5 contrary to paragraph 72 of
the NPPF which only allows for specific sites to be included in this period.
It relies upon sites achieving completions within the plan period, when the available evidence
demonstrates that there is no intention to deliver housing on these.
It relies upon three allocations achieving unprecedented and unrealistic delivery rates.
Once the supply is adjusted to take account of these factors, there is a supply of at most 46,687 homes
over the plan period, rather than the supply of 52,032 suggested in the GCLP.
Reliance on Strategic Sites
With regard to delivery, Rural Centres and Minor Rural Centres play only a limited role in the proposed
Development Strategy. Figure 9 of the Proposed Submission GCLP sets out that just 15% of planned
growth is directed to the rural area.
As referred to in the Bidwells note appended on Housing Need and Supply Matters, a strategy which
relies too heavily on large allocations risks a lack of delivery in the first 10 years of the plan period due to
the significant infrastructure required to service the very large allocations. This problem is highlighted in
paragraph 2.76 of the Proposed Submission GCLP, where the text acknowledges that it must “ensure a
deliverable plan but which is reliant on a significant level of infrastructure”. Senior Councillors at Cabinet
have also expressed their concerns to officers that this strategy is a risky one to adopt.
We consider this approach flawed as it heavily relies on two very large allocations set out under 2(c) (i)
Cambourne North (2550 dwellings in plan period) and 2(c) (ii) Grange Farm (2550 dwellings in the plan
period) which relies on significant infrastructure (namely Cambourne Railway Station to be delivered as
part of East West Rail and CSET respectively) coming forward in a timely manner to service these two
large strategic sites. Further ambiguity is compounded at paragraph 2.80 of the Regulation 19 Plan to the
strategy as the Cambridge Wastewater Treatment Works still makes an appearance as a potential
development site even though government funding for the project has been cancelled.
Our view is that the Proposed Submission GCLP relies too heavily upon the strategic sites, which will not
commence delivery until the latter half of the plan, after 2035. The plan period is 2024-2045. Our view is
that smaller sites in sustainable settlement locations will be needed for housing delivery in the first 10
years of the plan. If this does not happen the GCLP is unlikely to have sufficient sites available to make
up the shortfall in delivery, as required by government.
Small and Medium Sized Sites
Paragraph 73 of the NPPF (2024) stresses the importance of medium and small sites in meeting housing
requirements. Such sites are also essential for SME housebuilders and can often be delivered quickly
because they usually require limited infrastructure.
The draft Local Plan does not propose sufficient new housing allocations to address this requirement.
The evidence base explains this on the basis that it is challenging to identify enough small sites to meet
the 10% requirement, and doing so would undermine the Council’s development strategy and require the
release of Green Belt sites, conflicting with the aim of protecting the Cambridge Green Belt, because the
larger and better-served villages are within the Green Belt.
The Housing Delivery Addendum Update (2026) argues that, once windfall development of 4,953
dwellings on sites no larger than 1ha is included, 13.5% of homes over the plan period will be delivered
on small sites. However, relying mainly on windfall development to meet the 10% requirement does not give SME housebuilders the certainty needed to invest in site delivery. Across Greater Cambridge,
windfall delivery has generally declined over time.
Section 2 of the Greater Cambridge Housing Delivery Study Addendum Update (2026) reviews windfall
delivery between 2006 and 2024 and concludes that an allowance of 425 dwellings per annum is robust.
However, it does not explain why windfall delivery has declined or whether, particularly in South
Cambridgeshire, there are enough available sites to sustain windfall delivery at scale across the plan
period. Although the report uses data from 2006–2007 to derive an average windfall delivery rate of 470
dwellings per annum, Greater Cambridge has not delivered more than 470 windfall dwellings in any year
since 2016–2017. Even against the Council’s 425 dwellings per annum assumption, the average over the
previous seven years has been 395 dwellings per annum.
Furthermore, it is noted the Council states that upon adoption (2028) they will be able to demonstrate a
5.47-year housing land supply. However, the Authority’s decision to use the Liverpool method to assess
housing land supply is considered flawed. Paragraph 68-031 of the PPG establishes Sedgefield as the
preferred approach as it ensures any backlog in housing supply is addressed and not pushed back later
into the plan period – ensuring delivery is consistent throughout the plan period. Using the Sedgefield
approach means the land supply falls to 5.03 years and while this is marginal this should not be seen as
justification for using the Liverpool method as it is the Council’s decision to focus on larger sites that will
inevitably deliver later in the plan period.
This is symptomatic of the Authority’s historic and future preferred strategy to pursue strategic sites
which as outlined above face long lead in times before the delivery of housing can commence. The
marginal housing land supply when considering the Sedgefield approach is considered high risk and
does not reflect a positive strategy that will adequately deliver throughout the whole plan period. We
therefore reiterate that the Council should revise the Development Strategy to include additional medium
and small sites to supplement the housing supply of the Authority across the forthcoming plan period.
Distribution of Growth and the Rural Area
The proposed Development Strategy focuses new housing on a small number of strategic sites,
particularly in the rural area. Very few small and medium-sized housing sites are allocated in the rural
area, despite the NPPF (2026) recognising the important contribution such sites can make to housing
supply.
This approach will constrain the sustainable development of many rural settlements and their
communities. In particular, the lack of village allocations fails to support homes for local housing needs
during the plan period. Newly formed households may be forced to relocate to main settlements, new
settlements or elsewhere, away from family, community and support networks. This increases the need
to travel across Greater Cambridge, often by private car. It can also contribute to population imbalance,
with ageing village populations and falling primary school rolls, while new settlements experience
younger populations and pressure on services.
To maintain the vitality of historic rural settlements across Greater Cambridge, an appropriate level of
housing and employment growth is needed to support local high streets, services and facilities.
At present, the strategy proposes to deliver most development at new towns and settlements, including
Northstowe, Cambourne, Waterbeach and Grange Farm. While housing delivery at scale is supported,
the NPPF (2024) requires authorities to enable sufficient land to come forward to meet the housing
needs of the whole community, taking account of need, size, type and tenure (paragraphs 61–63).
Meeting the needs of the whole Authority requires a wider variety of land across the area to be identified
for development. Concentrating most housing at new settlements and new towns ignores the preference
many households may have to live in existing settlements and villages across the rural area. This
reduces market choice and competition, with likely adverse effects on house prices and availability.
A more balanced approach is required in the rural area, including a wider range of housing sites by size
and location. This is necessary to support sustainable communities, sustainable patterns of growth, the
needs and vitality of existing villages, and the wider rural economy.
In many villages, there is limited brownfield land within defined development extents to support housing
delivery under Draft Policy S/SH. Small windfall sites also provide limited affordable housing to meet
local needs. Specific housing allocations should therefore be made in some rural villages to promote
sustainable growth, support the rural economy, create mixed and inclusive communities, and maintain
local services.
Lack of Choice and Flexibility
The focus on large new settlements, urban redevelopment and sustainable urban extensions fails to
provide sufficient choice and flexibility for prospective homeowners. Not all purchasers will be able or
willing to buy in these locations. For example, young residents of villages in South Cambridgeshire may
wish to buy locally to remain close to family and childcare support, which may not be possible if they are
required to move to other allocated locations.
The lack of commitment to growth in sustainable rural settlements risks worsening Greater Cambridge’s
affordability crisis and pushing younger people out of their local communities and support networks.
Reliance on strategic settlements outside the Green Belt, and therefore further from Cambridge, is also
likely to increase car dependency.
New Homes and Jobs
NWBio objects to Policy S/JH. The policy is unsound as it is not positively prepared, not justified, not
effective and inconsistent with national policy.
These representations are supported by the enclosed Note on Housing Need and Supply Matters. This
concludes that the proposed housing requirement of Policy S/JH is unsound because:
I. It is not positively prepared as it does not meet even the minimum local housing need of the
standard method, let alone reflect the economic ambitions of the government as expressed
through the Local Growth Plan or respond sufficiently to the acute need for affordable housing.
II. It is not justified as it does not provide any justification for a housing requirement below the
minimum local housing need of the standard method, it does not even consider providing for a
level of housing which aligns with local and national economic growth ambitions, and it has not
considered whether a greater number of homes should be provided to better respond to
affordable housing needs.
III. It will not be effective, as it will not meet housing needs, support local and national economic
ambitions or deliver as much affordable housing as could sustainably be achieved.
IV. It is inconsistent with national policy as it does not meet the minimum local housing need of the
standard method contrary to the requirements of paragraph 62 of the NPPF, and it does not
support the planned economic growth contrary to the PPG (2a-040) and paragraph 86d of the
NPPF, and it is not informed by a consideration of a greater housing requirement to better meet
affordable housing needs contrary to the requirements of the PPG (2a-024).
In terms of the policy context, paragraph 69 of the NPPF (2024) notes an Authority may need to plan for
greater housing growth above their identified need to reflect growth ambitions linked to economic
development or infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024) confirms
that planning policies should seek to address potential barriers to investment, such as inadequate
infrastructure, services or housing, or a poor environment. The Regulation 19 Plan does not do this. This
message is translated into HO2(b) of the NPPF (2026) and it is clear that housing requirements within
local plans should be set higher than the figure identified within a housing needs assessment where appropriate. It is confirmed that such circumstances include where a higher housing requirement is
necessary to reflect growth ambitions linked to economic investment or infrastructure investment. Whilst
the GCLP will be assessed against the NPPF (2024), it is clear the direction being established by central
government is one of growth, with a particular focus on Cambridge and the surrounding region.
This need for growth is evidenced by national, regional and authority level investment in infrastructure
including the new Cambridge South Railway Station providing direct connectivity between Cambridge
Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and
progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context,
the commitment to East West Rail establishes the area as one benefiting from continued investment in
major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by
the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in
order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for
growth must be realised within the emerging Local Plan.
The proposed housing requirement of just 48,069 homes in the GCLP, which reflects the minimum
identified by the standard method, will clearly act to constrain the economic ambitions of the Local
Growth Plan contrary to paragraph 86d of the NPPF.
The fact that the GCLP is not planning for the level of growth necessary to support the economic
ambitions of the Local Growth Plan, which align with the economic objectives of the government is
underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even
consider the Oxford Cambridge Arc or the Cambridgeshire and Peterborough Combined Authority
(CPCA) Local Growth Plan (2025). Instead, it has been developed on the basis of standard economic
forecasts which are inevitably trend-based and so do not account for economic potential of the area as is
necessary to align with local and national economic ambitions. The EHNU draws its conclusions and jobs
and housing needs from the ‘central growth’ scenario with the ‘higher growth scenario’ dismissed.
However, it is noted the EHNU notes that the higher scenario could be achieved with step change in
investment.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater
job growth in the region will generate a derived demand for housing, creating an interdependency
between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of
slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and
homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full
growth potential of the Greater Cambridge economy.
With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central
government funding) and renewed commitment to delivery of growth in the Oxford–Cambridge Corridor
there is clear rationale for the Authority to reasonably adopt the high growth scenario. Furthermore,
whilst the Authority have met their identified needs for housing via the standard method it is
acknowledged the standard method does not take into account the specific growth agenda and focus on
Cambridge as an area of ‘supercharged growth’.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm
Cambridge’s position as an area capable of supporting and delivering high growth. Within this context
Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The
EHNU acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the
2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the
Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes
remain credible and should not be ruled out by policy. This requires revision to the proposed policy
wording.
We also note that the Draft GCLP (Regulation 18) required 2,463 dwellings per annum to deliver
employment growth of 66,000 jobs compared to the Proposed Submission (Regulation 19) which
requires delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period: this
therefore represents a decrease in housing delivery whilst reflecting an increase in job creation. The
EHNU reasons this in stating the fact that average household sizes are now larger, leading to an
increase in people of working age and more in-commuting which reduces the number of local people
required to fill jobs created. We raise concern this is an unsustainable approach to development strategy
and reflects a local housing market where many young people are unable to move out of their family
homes and move closer to or within Cambridge where jobs are located at key existing and development
employment centres such as CB1, Cambridge Biomedical Campus and Cambridge Science Park. We
advocate that the GCLP needs to address the affordability of housing within Greater Cambridge by
planning for increased growth and supply to reflect growing demand rather than embed the issue of
increasing household size. In doing so and making provision for increased housing stock in Greater
Cambridge in sustainable locations would ensure the Local Plan promotes more suitable patterns of
travel as required by paragraph 111 of the NPPF (2024) using planning polices to minimise the length of
and journeys required for employment.
