Greater Cambridge Local Plan: Proposed Submission

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Cottenham.

Vision for Greater Cambridge

Comment

Wates Manor Oak Homes has promoted the Land at Beach Road, Cottenham. The Vision for Greater Cambridge in the Reg.18 Draft Greater Cambridge Local Plan (draft GCLP) refers to increasing quality of life for communities, minimising carbon emissions, reducing car use, providing housing, supporting infrastructure and increasing green spaces.

As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the Vision for Greater Cambridge. The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. The development strategy is too focussed on the delivery of large strategic sites including an expanded Cambourne, existing new settlements at Northstowe, Waterbeach and Bourn Airfield, and a proposed new settlement at Grange Farm. The delivery timetable for infrastructure to support an expanded Cambourne and at Grange Farm is uncertain.

For all of the large strategic site allocations the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. The development strategy avoids directing development to the larger villages, including Cottenham regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs.

It is considered that the strategic priorities for the draft GCLP would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Cottenham.

Strategic Priorities

Comment

Wates Manor Oak Homes has promoted the Land at Beach Road, Cottenham. This was given the site reference 115466 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure.

As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:

• does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.

• does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. This outcome would not meet the climate change strategic priority. The development strategy is too focussed on the delivery of large strategic sites, where the timetable for the delivery of necessary infrastructure is uncertain in some cases, the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. It is considered that housing and affordable housing needs would not be met by a development strategy based on this approach and would not meet the homes strategic priority.

The development strategy avoids directing development to the larger villages, including Cottenham, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs. This approach does not support the residents or services and facilities in those villages, and would not meet the great places, homes, connectivity and infrastructure strategic priorities. It is noted that some green infrastructure opportunity areas identified in draft GCLP, including close to Cottenham, are unrelated to strategic development allocations that could support their delivery. In these circumstances those proposed green infrastructure opportunity areas are unlikely to be delivered, and this outcome would not meet the biodiversity and green spaces strategic priority.

It is considered that the strategic priorities for the draft GCLP would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Cottenham.

Proposed Amendments

The following changes should be made to Policy S/JH.

1. The housing requirement in Policy S/JH be reassessed to include a commuting adjustment.
2. An economic uplift be applied to reflect growth ambitions and infrastructure investment.
3. The housing target be increased to help address affordable housing need.
4. Consistent with the representations to Appendix C, a new policy is required in the draft GCLP to ensure that the housing requirements for neighbourhood plan areas are delivered.
5. Additional deliverable sites, including Land at Beach Road, Cottenham (HELAA reference 115466), be allocated to support housing delivery and plan flexibility, and ensure that the housing requirements for neighbourhood plan areas are delivered.

Object

These representations are submitted by Wates Manor Oak Homes in its capacity as a site promoter with regards to Land at Beach Road, Cottenham. This was given the site reference 115466 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026, whereby they are seeking a housing allocation. The site is located at the junction of Beach Road and Long Drove, Cottenham.

Policy S/JH of the draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,069 dwellings.

The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire). In summary, the housing target is not consistent with national policy because upward adjustments for growth and affordable housing have not been considered.

Furthermore, it is important to note that for 5-Year Housing Land Supply purposes, the 2025 Housing Delivery Test results published in August 2026 now require Cambridge City to apply a 20% buffer to its annual housing requirement figure of 1,085 dwellings. This results in a new annual housing requirement figure of 1,302 dwellings.

In respect of South Cambridgeshire, its required buffer of 5% increases its annual standard method requirement from 1,204 to 1,264 dwellings.

Consequently, rather than the average 2,289 dwellings needed per annum under the standard methodology, together the two authorities will instead need to be able to deliver 2,566 dwellings per annum in order to meet their latest 5-Year Housing Land Supply requirement and demonstrate that their Joint Plan is sound. This equates to a total of 12,830 dwellings (2,566 x 5).

This demonstrates the importance of ensuring that the Local Plan contains a ready pipeline of small and medium sized sites that are capable of delivering new housing in the early years of the Plan period, prior to many of Greater Cambridge’s larger strategic sites being capable of delivery due to associated infrastructure provision constraints.

We believe that the job target is not aligned with the housing target. It is considered that a job target that is higher than the housing target would require potential employees to commute into Greater Cambridge to fill those jobs. This outcome would lead to an increase in in-commuting to Greater Cambridge. It is anticipated that most of the in-commuting would be by car, particularly if public transport options are not available or the delivery of transport infrastructure projects are subject to unconfirmed funding decisions and associated development.

Wates Manor Oak Homes strongly objects to the overall housing numbers proposed within the plan and believes that these require an upwards revision. The jobs and housing targets in the draft Plan are not aligned. A higher jobs target relative to housing provision will necessitate increased in-commuting to meet labour demands. Earlier evidence, specifically the 2023 Greater Cambridge Employment and Housing Evidence Update, derived its housing target using a Central Growth Scenario, preferred 2011 Census commuting data, and a 1:1 commuting adjustment to ensure closer alignment between job growth and housing need. However, the 2025 Greater Cambridge Employment and Housing Needs Update did not apply any equivalent adjustment. Nor is any reference to this contained within the 2026 Jobs Topic Paper.

While the 2025 Strategy Topic Paper acknowledged the importance of commuting patterns in understanding the jobs–housing relationship, it similarly failed to apply a commuting adjustment to the housing requirement. Consequently, despite recognising commuter dynamics, the Topic Paper and the updated evidence base did not translate this into the housing target. The same deficiency applies to the content of the 2026 Development Strategy Topic Paper.

This omission results in a housing requirement that remains too low to support the proposed jobs growth, exacerbates the risk of increased in-commuting, and undermines the effectiveness and soundness of Policy S/JH.

Policy HO1: Assessing the Need for Homes within the Framework expects the standard method in Annex D to be used. The policy also requires local authorities to assess the minimum number of dwellings needed, as well as the size, type and tenure of housing or other accommodation needed for different groups, including for example those with an affordable housing need.

Policy HO2: Setting Requirement Figures for Homes states in section 3 (b) that the requirement may “be higher than the overall figure identified in the local housing needs assessment where appropriate. This includes situations where a higher housing requirement is necessary to meet the needs of neighbouring areas, or to reflect growth ambitions linked to economic development or infrastructure investment.…”.

Policy HO13: Build Out of Residential and Strategic Sites within the NPPF (August 2026) confirms the Government’s objective to significantly boost the supply of housing.

Paragraph 008 (ID. 67 - Housing needs of different groups) in the Planning Practice Guidance states in part that “An increase in the total housing requirement included in the plan may need to be considered where it could help deliver the required number of affordable homes”.

The housing target in Policy S/JH is based on the standard method only, with no adjustments for growth linked to economic development and infrastructure investment or to meet affordable housing needs, all of which are relevant to Greater Cambridge.

For jobs, the Greater Cambridge Employment and Housing Evidence Update 2025 (EHNU 2025) draws on the latest available data to identify the “central” most likely future jobs forecast taking account of what is unique about the Greater Cambridge economy, including life science and ICT sectors – priority sectors identified in the Cambridgeshire and Peterborough Local Growth Plan. The Draft Plan specifies that this position was reconfirmed by the Review of economic data, context and representations 2026. The central forecast assumes strong growth of around 3,500 additional jobs per annum or more through to 2045 – continuing the recent period of rapid growth seen in Greater Cambridge’s Knowledge Intensive sectors, but also building in an assumption that there will be slower or contracting periods and unforeseen shocks, which are likely in most economies. We consider that we should plan for this forecast of the most likely level of new jobs.

As a result of the Government’s establishment of the Cambridge Growth Company, and significant infrastructure investment (including East West Rail, Cambridge South Station and the Greenways network), we believe that the Greater Cambridge Authorities are taking an overly pessimistic approach to the anticipated level of job creation, and that an economic uplift should be applied to the housing target.

The accompanying Jobs Topic Paper references the Get Cambridgeshire and Peterborough Growing, the Cambridgeshire and Peterborough Combined Authority Local Growth Plan, approved in October 2025, identifies Greater Cambridge as Global City Cambridge Opportunity Zone.

“This Opportunity Zone is focused on turbocharging an already globally recognised industry. It will continue to concentrate priority sectors in Cambridge while unblocking key infrastructure gaps with a focus on our shared priorities with Government. Comprised of nine key projects, and interventions focused on making Cambridge as globally competitive as possible, this Opportunity Zone is of the utmost strategic importance, not only for the area, but for the nation.”

The sector focus in the area will be Life Sciences, Advanced Manufacturing & Materials; Digital Technologies; Defence; Agri-Food & Tech and Energy & Clean-Tech. The key projects within Greater Cambridge area are A10 improvements, Cambourne, Cambridge East, North East Cambridge and Mass Rapid Transit. The interventions are securing global industries into Cambridge; establishing an Ox-Cam Institute for innovation led growth and exploring venture capital.

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:

• There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world’s most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.

• Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

These are just two examples that demonstrate the mismatch between the numbers of job needed and the number of homes that will actually be provided within Greater Cambridge over the course of the plan period.

The Greater Cambridge City Deal recognised the strong relationship between housing supply and economic performance, noting that constrained housing availability and affordability have influenced house prices, commuting patterns, and employers’ ability to attract and retain staff. The Cambridgeshire and Peterborough Devolution Deal similarly committed to substantial economic growth, including a target to double economic output over 25 years.

In 2024, Government established the Cambridge Growth Company to help maximise Cambridge’s economic potential and deliver nationally significant growth. The Greater Cambridge Development Corporation was established by the government on 23 July 2026. It is a statutory delivery body set up as a new local-national partnership, to unlock the long-term sustainable economic future of Greater Cambridge.

Building on the foundations laid by the Cambridge Growth Company, the Development Corporation marks the next phase of the government's commitment to achieving nationally significant economic growth through infrastructure-led development.

In addition, there are also several planned and proposed infrastructure projects that should inform how the housing target should be adjusted. These include East West Rail, the Cambourne to Cambridge Busway, the Cambridge South East Transport project, the Waterbeach to Cambridge Busway, Cambridge Eastern Access, and Cambridge South Station. In addition, the Greater Cambridge Partnership is progressing a network of greenways to improve active travel connections between surrounding villages and Cambridge. There is also a need to take on board the development pressures generated by recently provided major infrastructure, in particular, the recent opening of the Cambridge South Railway Station.

Finally, the Iceni Housing Needs of Specific Groups in Cambridge and South Cambridgeshire Report (August 2025) provides an assessment of the housing requirements of various groups, including the need for affordable housing. Chapter 7 focuses specifically on affordable housing need and identifies a significant shortfall across Greater Cambridge.

The Report estimates that 1,083 affordable homes are needed each year for households unable to buy or rent on the open market across Greater Cambridge, excluding those who can afford to rent but not buy (Paragraph 7.62). It also presents an alternative scenario that removes households who are already housed from the calculation. Under this approach, the annual requirement would be 425 affordable homes in Cambridge and 318 in South Cambridgeshire (Paragraph 7.63), giving a combined figure of 743 affordable homes per year.

The Report acknowledges the complexity of assessing affordable housing needs, including the fact that needs change over time, and therefore advises that these annual figures should not be multiplied to produce a total for the entire plan period. Nevertheless, the Report concludes that no adjustment to the draft GCLP housing target is required to address affordable housing need. This conclusion is not justified in our opinion, particularly given that affordable housing delivery within Greater Cambridge is likely to be adversely impacted by the likely lower percentage of affordable housing provision likely to be achievable at many of its major allocation sites due to the high cost of necessary infrastructure provision needed, which will adversely affect viability.

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year—below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy-compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm.

If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Cottenham be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land at Beach Road, Cottenham can support early housing delivery and help meet the revised requirement.

Given all of the above, Wates Manor Oak Homes strongly believes that the housing target in Policy S/JH should be reassessed, with an upward adjustment applied to ensure that the Local Plan is sound and meets its duty to support economic growth ambitions, planned infrastructure investment and affordable housing provision within villages.

Proposed Amendments

The proposed changes to Policy S/DS: Development Strategy are as follows:

1. Housing delivery assumptions for all of the strategic sites be reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites (also considering the need to increase the overall housing target).

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Manor Homes site at Beach Road, Cottenham (HELAA reference 115466).

Object

Policy S/DS of the draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. Most of the existing new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm would also be reduced for the same reasons. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed.

Furthermore, it is important to note that for 5-Year Housing Land Supply purposes, the 2025 Housing Delivery Test results published in August 2026 now require Cambridge City to apply a 20% buffer to its annual housing requirement figure of 1,085 dwellings. This results in a new annual housing requirement figure of 1,302 dwellings.

In respect of South Cambridgeshire, its required buffer of 5% increases its annual standard method requirement from 1,204 to 1,264 dwellings.

Consequently, rather than the average 2,289 dwellings needed per annum under the standard methodology, together the two authorities will instead need to be able to deliver 2,566 dwellings per annum in order to meet their latest 5-Year Housing Land Supply requirement and demonstrate that their Joint Plan is sound. This equates to a total of 12,830 dwellings (2,566 x 5).

This demonstrates the importance of ensuring that the Local Plan contains a ready pipeline of small and medium sized sites that are capable of delivering new housing in the early years of the Plan period, prior to many of Greater Cambridge’s larger strategic sites being capable of delivery due to associated infrastructure provision constraints.

The Minor Rural Centres, including Cottenham, are referred to as part of the development strategy but there are limited allocations in this category of settlement. It is considered that the growth of the more sustainable villages should be part of the development strategy for draft GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Cottenham falls within this category.

Wates Manor Oak Homes has promoted the Land at Beach Road, Cottenham over a lengthy period of time. In April 2018 it submitted an outline planning application (S/0012/18/OL) with all matters reserved except for access for the erection of up to 50 dwellings (use class C3) and associated works including access, car and cycle parking, open space and landscaping.

The promoted development would support and boost the existing services and facilities in the village. It is a medium sized site that could be delivered relatively quickly. It is accessible by sustainable modes of transport. The site would deliver affordable housing to meet the identified needs for the village.

Proposed Amendments

The proposed changes to the Settlement Hierarchy set out in Policy S/SH are as follows.:

1. The Settlement Hierarchy be reviewed following an assessment of the sustainability credentials of each settlement in the district.

2. The GCLP undertake a review of the capacity of the most sustainable villages in South Cambridgeshire, including Minor Rural Centres such as Cottenham, to determine whether additional development can be accommodated within existing development framework boundaries. Where the assessment identifies no suitable internal sites to meet identified housing and affordable housing needs, the Local Plan should allocate additional land at the edges of these settlements to ensure that growth is appropriately directed, sustainably delivered, and consistent with the Plan’s stated objectives. If the indicative maximum scheme size limits are no longer relevant, they should be deleted.

Object

Policy S/SH of the draft GCLP defines the settlement hierarchy. Wates Manor Oak Homes has promoted the Land at Beach Road, Cottenham.

Cottenham is defined as a Minor Rural Centre in the settlement hierarchy. Minor Rural Centres have an indicative maximum scheme size of 30 dwellings within the defined development extents of those villages.

While the policy identifies Rural Centres, Minor Rural Centres and Group Villages as part of the development strategy, it does not allocate any new residential development in these settlements, including those, such as Cottenham, that are demonstrably highly sustainable. The absence of such an assessment means the settlement hierarchy is applied rigidly rather than being evidence-led, with no consideration given to whether directing growth to sustainable villages could support the Local Plan’s wider objectives relating to housing delivery, affordable housing provision, service retention, and reduced commuting distances.

There does not appear to have been any evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

Any development opportunities that do exist would be small scale and would not deliver affordable housing or provide any meaningful support to existing services and facilities. In these circumstances, the indicative maximum scheme size of 30 dwellings for Minor Rural Centres is irrelevant to Cottenham.

Cottenham contains a good range of services and facilities, and employment opportunities. Key village facilities include a doctor’s surgery, pharmacy, primary school, village college, church, shops, village hall, library, and a community sports centre, and access to the Guided Busway for wider transport.

Cottenham possesses the following bus route services:

• 8: Cambridge - Cottenham
• 8A: Cambridge – Orchard Park
• 8A: March – Milton P&R
• 110: Ely – Cottenham - Impington

The village is well-related to significant employment opportunities:

Immediate Local Employment & Industrial Areas

• Cottenham Village: Local demand exists for care work (e.g., Bupa Cottenham Court), education (Chestnut Nursery School), and retail/services.
• Waterbeach (approx. 3 miles): Home to the Cambridge Research Park, which hosts various tech, scientific, and office-based firms.
• Milton (approx. 4 miles): Offers significant employment opportunities, including the Cambridge Science Park and various retail/industrial roles.
• Longstanton (approx. 4 miles): Nearby business parks and specific employer sites, such as the Village Vet Group.

Major Regional Hubs (Accessible by Road/Bus)

• Cambridge Science Park & Northern Fringe: Located just south of Milton, this is a major hub for science, technology, and engineering, easily accessed from the A10.
• Cambridge City Centre: 6-7 miles south, offering a broad range of jobs in education, healthcare (Cambridge University Hospitals), retail, and professional services.
• Ely (approx. 10 miles north): Provides industrial and logistics employment, with a busy recruitment market (e.g., Busy Bee Recruitment).
• Huntingdon (approx. 10-12 miles west): A significant hub for warehouse, logistics, and manufacturing roles, including businesses like Dreams Ltd and

However, there has been no review of the capacity of settlements to accommodate additional development for draft GCLP, or whether the development threshold limits remain relevant if no sites are available. There appears to be no major residential development opportunities within the development framework boundary of Cottenham.

Any development opportunities that do exist would be small scale and would not deliver affordable housing or provide any meaningful support to existing services and facilities. In these circumstances, the indicative maximum scheme size of 30 dwellings for Minor Rural Centres is irrelevant to Cottenham.

As set out in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Cottenham to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

Proposed Amendments

The proposed changes to Policy S/DE: Defined Development Extents are as follows:

1. the Council undertake a review of the capacity of the more sustainable settlements, including Minor Rural Centres, to determine whether additional development can be accommodated within the current development framework boundaries. Where no suitable capacity exists, the Local Plan should allocate appropriate village-edge sites to ensure future housing and affordable housing needs can be met in sustainable locations such as Cottenham.

2. Wates Manor Oak Homes has promoted the Land at Beach Road site in Cottenham, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Object

Policy S/DE of the draft GCLP set out the approach to development within and outside the defined development extents of villages. Wates Manor Oak Homes do not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire, including Cottenham, have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018.

The Cottenham Neighbourhood Plan (NP) was made in May 2021. The NP only included provision for around 15 additional homes. These being three brownfield sites within the village centre. The Plan is now over 5 years old, so is no longer up to date in accordance with the new NPPF with regard to up-to-date housing allocations.

The currently defined development framework boundary for Cottenham means that limited development would take place in this village. The housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

Given these characteristics, it is clear that retaining Cottenham’s development extent in its current form severely limits the ability of the village to meet housing and affordable housing needs, to support local services, and to deliver wider community benefits. Whilst Wates Manor Oak Homes does not seek a direct amendment to the wording of Policy S/DE itself, these representations emphasise that defined development extents should be subject to a full review to ensure they accurately reflect the development potential and sustainability of individual settlements. Where that review concludes, as in Cottenham, that there is no capacity within existing boundaries, the Local Plan should allocate appropriate village-edge sites in the most sustainable locations in accordance with the Settlement Hierarchy. Doing so would enable planned growth to be directed where it can be sustainably accommodated, support the vitality of rural communities, and help deliver the affordable housing that smaller infill schemes cannot provide.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land at Beach Road, Cottenham (HELAA Site Ref. 115466) are as follows:

1. Land at Beach Road, Cottenham (HELAA Site Ref. 115466) be allocated in the Local Plan with the following requirements:

• Residential Site Area: 2.4 hectares

• Indicative capacity: 50 dwellings, including a policy-compliant proportion of affordable housing

• Provision of landscaping and a biodiversity net gain

Object

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct development to the more sustainable villages, and there are exceptional circumstances to release land from the Green Belt. All these factors indicate that additional allocations should be made in the draft GCLP to meet development needs.

Cottenham contains a good range of services and facilities, and employment opportunities. Key village facilities include a doctor’s surgery, pharmacy, primary school, village college, church, shops, village hall, library, and a community sports centre, and access to the Guided Busway for wider transport.

Cottenham possesses the following bus route services:
• 8: Cambridge - Cottenham
• 8A: Cambridge – Orchard Park
• 8A: March – Milton P&R
• 110: Ely – Cottenham - Impington

The village is well-related to significant employment opportunities:

Immediate Local Employment & Industrial Areas

• Cottenham Village: Local demand exists for care work (e.g., Bupa Cottenham Court), education (Chestnut Nursery School), and retail/services.
• Waterbeach (approx. 3 miles): Home to the Cambridge Research Park, which hosts various tech, scientific, and office-based firms.
• Milton (approx. 4 miles): Offers significant employment opportunities, including the Cambridge Science Park and various retail/industrial roles.
• Longstanton (approx. 4 miles): Nearby business parks and specific employer sites, such as the Village Vet Group.

Major Regional Hubs (Accessible by Road/Bus)

• Cambridge Science Park & Northern Fringe: Located just south of Milton, this is a major hub for science, technology, and engineering, easily accessed from the A10.
• Cambridge City Centre: 6-7 miles south, offering a broad range of jobs in education, healthcare (Cambridge University Hospitals), retail, and professional services.
• Ely (approx. 10 miles north): Provides industrial and logistics employment, with a busy recruitment market (e.g., Busy Bee Recruitment).
• Huntingdon (approx. 10-12 miles west): A significant hub for warehouse, logistics, and manufacturing roles, including businesses like Dreams Ltd and

We note that the Housing Needs of Specific Groups in Cambridge and South Cambridgeshire Report (August 2025) identifies in paragraph 5.5 that the lowest value areas in Greater Cambridge are to the north of the city (Chesterton and Kings Hedges) and around Cambourne, Bar Hill and Cottenham in South Cambridgeshire. This means that housing is likely to be more affordable in Cottenham for new house buyers in comparison within many other areas of Greater Cambridge.

Paragraph 12.117 references the work of the Cottenham Community Land Trust - A Community Land Trust aiming to improve the availability of affordable housing in the parish of Cottenham, South Cambridgeshire. The allocation of Land at Beach Road would assist in relation to addressing affordable housing needs.

In April 2018, Wates Manor Oak Homes submitted an outline planning application (S/0012/18/OL) with all matters reserved except for access for the erection of up to 50 dwellings (use class C3) and associated works including access, car and cycle parking, open space and landscaping. The application was refused and ultimately went to appeal. At which, in dismissing the appeal, the Inspector acknowledged that the proposed scheme would deliver local benefits. However, he considered that the proposed scheme would be contrary to the newly adopted development plan.

The subsequent SHLAA Site Assessment in respect of Land at Beach Road, Cottenham (40251) scored the site very positively with only green or amber scores being recorded.

Wates Manor Oak Homes has promoted the Land at Beach Road, Cottenham (HELAA Site Ref. 115466). There are no significant constraints to development at this site. The latest Site Assessment noted:

• The Site is wholly within Flood Zone 1

• In terms of landscape, development of this site would continue village extensions along Beach Road, similar to development patterns on other approaches.

• In terms of biodiversity, boundary habitats including hedgerows, drains and mature trees could be retained. There are no designated sites nearby.

• The Site is wholly outside protected open space. Detrimental open space impacts are not anticipated.

• There would not be a detrimental impact on any designated or non-designated heritage assets.

• In terms of site access, the proposed site is acceptable in principle subject to detailed design. Any potential impact on the functioning of trunk roads and/or local roads could be mitigated.

• The site is capable of being developed to provide healthy internal and external environments in regard to noise / vibration / odour / light pollution after careful site layout, design and mitigation.

• Site does not lie within an AQMA. Minimal traffic impact on AQMA.

The application site is outside Cottenham's Conservation Area on the eastern edge of the village, just outside the Cambridge Green Belt, which lies to its immediate south.

The proposed development will essentially create a new 'village edge’. It will improve the village
edge by good design with an outward facing development and quality landscaping. It seeks to create a strong, but sensitive edge addressing the open countryside with enhanced ecological and landscape characteristics.

Sustainable Urban Drainage Systems (SUDS) will be utilised on the site. Surface water will discharge to the existing watercourse located adjacent to Beach Road and will be attenuated to greenfield runoff rates using a detention basin. Foul water will discharge to Anglian Water's foul sewer network via a new pumping station.

The site can be accessed off Beach Road with a footway link via Long Drove. Visibility Splays, relevant to the speed limit, will be acknowledged and adhered to. The proposed development is located in a sustainable location and is located within acceptable walking and cycling distance of local facilities, including the primary school. The site offers many opportunities for residential development including:

• Long distance views into the site are limited, however, some long-distance views across the site and out towards the north east can be explored via carefully selected and located boundary planting.

• The built form will be concentrated to the western half of the site, providing opportunities for new landscaping and green open space along the more sensitive boundaries.

• Providing new, accessible green public open space retaining specific landscape features with improved site wide ecology.

• Creating strong vistas and 'places' within the site, such as a central square or feature area. These areas will break up the scheme and are relevant for the site’s rural location.

• Improving boundary conditions, including security, with additional planting. Also, the retention of the existing field hedge.

• Identifying a zone for the fowl water pumping station so it is hidden but accessible.

It is evident from the aforementioned HELAA Site Assessment that the land at Beach Road, Cottenham site is suitable for housing development. Furthermore, it would be capable of delivery in the early years of the Plan period prior to when many of Greater Cambridge’s larger allocations would be capable of delivering housing completions.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land at Beach Road site in Cottenham (HELAA Site Ref. 115466) are as follows:

1. A new policy be included within the draft GCLP to deal with the potential scenario where a neighbourhood plan is not updated or does not allocate land to meet the identified housing requirement identified in Appendix C. This requested change would ensure that the identified housing requirement for villages are met during the plan period.

2. It is requested that the identified housing requirements in Appendix C include an adjustment so that affordable housing needs of villages are met during the plan period. The housing requirement for Cottenham should also ensure that the affordable housing needs of the village are met.

Comment

Policy I/ST of the draft GCLP seeks to ensure that development promotes sustainable transport in order to reduce reliance on the car. Paragraph 110 of the NPPF expects the planning system to actively manage patterns of growth to support transport objectives. It is expected that significant development would be focused on locations which are or can be made sustainable, by limiting the need to travel and offering a genuine choice of transport modes. Paragraph 115 identifies factors that should be considered when assessing sites to be allocated for development, including that sustainable transport modes are prioritised, safe and suitable access can be provided, and the impacts on the transport network and highway safety can be mitigated. Policy I/ST is broadly consistent with this national policy.

Wates Manor Oak Homes has promoted the Land at Beach Road, Cottenham. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Cottenham to implement this approach.

Cottenham is defined as a Minor Rural Centre in the settlement hierarchy.

Cottenham contains a good range of services and facilities, and employment opportunities. Key village facilities include a doctors surgery, pharmacy, primary school, village college, church, shops, village hall, library, and a community sports centre, and access to the Guided Busway for wider transport.

Cottenham possesses the following bus route services:

• 8: Cambridge - Cottenham
• 8A: Cambridge – Orchard Park
• 8A: March – Milton P&R
• 110: Ely – Cottenham - Impington

The village is well-related to significant employment opportunities:

Immediate Local Employment & Industrial Areas

• Cottenham Village: Local demand exists for care work (e.g., Bupa Cottenham Court), education (Chestnut Nursery School), and retail/services.
• Waterbeach (approx. 3 miles): Home to the Cambridge Research Park, which hosts various tech, scientific, and office-based firms.
• Milton (approx. 4 miles): Offers significant employment opportunities, including the Cambridge Science Park and various retail/industrial roles.
• Longstanton (approx. 4 miles): Nearby business parks and specific employer sites, such as the Village Vet Group.

Major Regional Hubs (Accessible by Road/Bus)

• Cambridge Science Park & Northern Fringe: Located just south of Milton, this is a major hub for science, technology, and engineering, easily accessed from the A10.
• Cambridge City Centre: 6-7 miles south, offering a broad range of jobs in education, healthcare (Cambridge University Hospitals), retail, and professional services.
• Ely (approx. 10 miles north): Provides industrial and logistics employment, with a busy recruitment market (e.g., Busy Bee Recruitment).
• Huntingdon (approx. 10-12 miles west): A significant hub for warehouse, logistics, and manufacturing roles, including businesses like Dreams Ltd and

As set out elsewhere in these representations, amendments should be made to the development strategy for the draft GCLP to direct development to the more sustainable villages including Cottenham.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land at Beach Road site in Cottenham (HELAA Site Ref. 115466) are as follows:

1. A new policy be included within the draft GCLP to deal with the potential scenario where a neighbourhood plan is not updated or does not allocate land to meet the identified housing requirement identified in Appendix C. This requested change would ensure that the identified housing requirement for villages are met during the plan period.

2. It is requested that the identified housing requirements in Appendix C include an adjustment so that affordable housing needs of villages are met during the plan period. The housing requirement for Cottenham should also ensure that the affordable housing needs of the village are met.

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. There is a made Cottenham Neighbourhood Plan (made May 2021), which makes no allocations for housing. However, Figure 14 lists Cottenham’s possible development sites, which includes Wates Manor Oak Homes’ Land at Beach Road site.

The housing requirement for Cottenham in Appendix C is 127 dwellings between 2025 and 2045. It is positive that a housing requirement is identified for Cottenham, but it is considered that additional policy support is required in draft GCLP to ensure that the additional housing is actually delivered in Cottenham during the plan period. It is suggested that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

The Cottenham Neighbourhood Plan made in May 2021 does not allocate any land for development. It was not able to release land from the Green Belt because the adopted South Cambridgeshire Local Plan 2018 does not include a policy that would have allowed that to happen. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Cottenham Neighbourhood Plan will be updated to address the housing requirement identified in Appendix C for the village. There is no policy in draft GCLP that would ensure the identified housing requirement for Cottenham is delivered during the plan period if the Cottenham Neighbourhood Plan is not updated. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages. For example, South Cambridgeshire District Council’s ‘Housing Statistical Information Sheet for 2022 (published September 2022) identified an affordable housing need of 91 dwellings for those with a local connection to Cottenham.

The promoted Wates Manor Oak Homes development at Land at Beach Road would include housing and affordable housing to meet local needs of the village.

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the larger and more sustainable villages including Impington.

Vision for Greater Cambridge

COMMENT

Wates Manor Oak are promoting a site in Impington. The Vision for Greater Cambridge in the Reg.19 Proposed Submission Greater Cambridge Local Plan (draft GCLP) refers to increasing quality of life for communities, minimising carbon emissions, reducing car use, providing housing, supporting infrastructure and increasing green spaces. Wates Manor Oak previously commented on the Vision at Reg.18 stage.

As set out in these representations, the proposed housing target, the development strategy and the selected allocations for draft GCLP are unlikely to fully deliver the Vision for Greater Cambridge. The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. The development strategy is too focussed on the delivery of large strategic sites including an expanded Cambourne, existing new settlements at Northstowe, Waterbeach and Bourn Airfield, and a proposed new settlement at Grange Farm. The delivery timetable and funding for infrastructure to support an expanded Cambourne and at Grange Farm is uncertain. For all of the large strategic site allocations the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. The development strategy avoids directing development to the more sustainable villages, including Impington, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs. Wates Manor Oak made these comments at Reg.18 stage, but those previous concerns have not been considered, which means that the Vision will still not be delivered.

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the larger and more sustainable villages including Impington.