Greater Cambridge Local Plan: Proposed Submission

In order to overcome the issues highlighted in this representation and the enclosed Note on Housing
Need and Supply matters, and progress a sound Local Plan, it will be necessary to undertake the
following additional work and revise the proposed housing requirement accordingly:
• Increase the housing requirement to reflect as a minimum the minimum local housing need of
the standard method for 48,090 homes.
• Prepare housing projections which align with the economic ambitions set out in the recently
adopted Local Growth Plan, which the CPCA suggest will necessitate a requirement of at least
59,409 homes but potentially substantially more.
• Consider whether it would be sustainable to deliver a greater number of homes to better respond
to the acute need for affordable housing.
• In light of the available evidence, this will necessitate a requirement of at least 59,409 homes
over the plan period to support the local and national economy, rather than the proposed
insufficient housing requirement of 48,069 homes which falls short of meeting even the minimum
local housing need and pays no regard to the level of housing necessary to support the local and
national economy.
It is requested that the GCLP should allocate additional sites in Greater Cambridge to directly respond to
the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth
potential. The Site is available for allocation and can assist in delivering new housing development in a
sustainable way.

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.
II.
III.
IV.
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.
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.
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.
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 Proposed Submission 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 Local Growth Plan. 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
Employment and Housing Needs Update 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.

• Revise housing supply assumptions by removing unrealistic windfall, delivery and build-out
assumptions.
• Reduce reliance on a small number of large strategic sites with significant infrastructure
dependencies.
• Allocate additional small and medium-sized housing sites to improve deliverability and support
SME builders.
• Direct a greater proportion of growth to sustainable rural settlements and villages.
• Provide specific village housing allocations rather than relying primarily on windfall development.
• Create a more balanced distribution of growth across Greater Cambridge.
• Increase housing choice, flexibility and affordability by providing a wider range of site sizes and
locations.
• Use a more robust housing land supply approach and ensure sufficient delivery in the early
years of the plan.

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.
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.
II.
III.
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.
Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. Given this experience we are very concerned that the draft
strategy for the Plan (Policy S/DS) relies very heavily on allocating significant dwelling numbers on a
small number of very large sites. These sites rely on the timely provision of strategic scale infrastructure
which must be in place before these sites can be delivered.
The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (4,500 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway Travel Hub on the adjacent side of the
A505. The draft Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We
believe this is highly unlikely for the reasons set out in this representation.
The NPPF 2024 requires in paragraphs 61, 69 and 78 local plans to allocate additional housing land
where it cannot demonstrate an adequate housing supply. Paragraphs 72 to 77 encourage planning
authorities to identify a sufficient supply and mix of sites, support opportunities for large-scale
development, and make realistic assessments of delivery rates, including for strategic urban
extensions and new settlements. We do not believe these larger allocations will deliver until late in the
plan period leaving a hole in delivery in the early part the plan (as evidenced within the Housing Needs
and Matters Report). This hole needs to be filled with deliverable and sustainable sites where housing,
including affordable housing is needed. The NPPF 2024 at paragraph 73 recognises the importance of
smaller sites as they tend to be built more quickly, and allocating such sites will support small and
medium-sizes enterprise housebuilders.
Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that the chosen draft strategy approach sets the draft local plan on a path of over
reliance on these sites which is problematic for the following reasons:
The speed at which these developments can deliver homes is very often far slower than the Councils
have envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the large
strategic sites in the adopted Development Plan, may now be delivering at an appropriate rate, however
they came on stream years later than anticipated.
The Councils have not identified any new allocations for housing in the rural area which fails to support
the vitality of the rural area and existing settlements. We believe that this decision, has been made in
part, to avoid development in the Green Belt, and therefore fails to strike a more balanced approach to
housing delivery across the Plan period.
The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from the
settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest preference to
deliver jobs and homes, clearly fails to distinguish between what may be sustainable locations in the rural
area which is clearly capable of delivering an appropriate scale of development in the first half of the plan
period which is likely to experience a significant deficit due to the infrastructure required by the large
strategic sites allocated.
Policy S/SH effectively creates a juxtaposition whereby it is recognised that growth within Rural
Settlements need not be unduly constrained as it benefits from a reasonable level of services, facilities
and accessibility to the main urban area; yet in failing to allocate any sites, growth is basically
constrained to the settlement boundaries where windfall opportunities are restricted. Rural Settlements
benefitting from well-established and diverse range of local services and facilities that can support both
existing and future residents. These include schools, early years provision, convenience retail with post
office, a health centre, library, community facilities, and recreational spaces.
The focus upon large new settlements, urban redevelopment and SUEs fails to properly consider the
need to offer sufficient choice and flexibility to perspective homeowners. Not all prospective purchasers
will be able to, or wish to buy, in these locations whether due to affordability constraints, lifestyle
preferences, or housing type availability. It is therefore important to allocate housing sites in settlement
locations in order to deliver more affordable housing and a broader range of options for housing choice.
Figure 9 in the plan identifies only 15% of the housing allocation for this local plan in the rural area which
is the lowest amount for several decades and more needs to be made of the rural area option in this local
plan.
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 delver 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.

Additional sites should be allocated with the ambition to boost housing delivery within the first 10 years of
the plan period.

The draft policy sets out an 8-point mechanism with further details in Appendix E for dealing with under
delivery of housing allocations in the plan. The policy requires the two Councils to monitor the
implementation and performance of the Local Plan against the monitoring indicators set out in the
monitoring framework, set out in Appendix E: Monitoring Framework. However, results will be reported
on annually which is not reactive enough to deal with under delivery. This is clearly illustrated by the
current number of unsolicited planning applications and appeals taking place in the district because the
current adopted local plan allocations are not delivering in a timely manner. The policy states –
If, through monitoring, it appears that policies and allocations are not being achieved, the following
mechanisms will be triggered:
a. Review of housing and employment land supply and allocations;
b. Action to bring forward sites for development, wherever possible in partnership with landowners and
developers;
c. Action to bring forward development on previously developed land;
d. Action to secure the timely provision of infrastructure;
e. Review of all, or relevant parts of, the Local Plan;
f. Review Development Management processes; or
g. Consider undertaking cooperation with other local authorities, including through duty to cooperate. 
The above mechanisms will not lead to housing delivery in a timely manner as proven by current
applications and appeals. Thus, the Authority should allocate a number of sustainable and deliverable
housing sites in the local plan to serve delivery in the first 10 years of the plan due to the envisaged lack
of delivery on the very large allocations in the Proposed Submission GCLP which require significant
infrastructure to deliver them.

We advocate HELAA Site 115482 should be allocated for residential development

Whilst we do not object to housing in principle we object to the draft emerging local plan’s over-reliance
on large, infrastructure-dependent sites and failure to allocate smaller, sustainable rural sites like Land
South of Priest Lane, Willingham. Separate representations have been made to draft policy S/DS as part of this consultation. The Site is able to make any necessary improvements to local or national
infrastructure arising through the proposals and provides a sustainable location for needed residential
development. Allocating this Site for residential development would support the delivery of homes in a
highly sustainable location.

Land Off Priest Lane, Willingham
Within the Representations outlined above we have accounted for fundamental flaws in the proposed
spatial strategy being pursued by Greater Cambridge within the emerging Local Palan
Site Location
The Site is located within the village of Willingham which is identified in the settlement hierarchy as a
Minor Rural Centre. As a Minor Rural Centre, the village benefits from a well-established and diverse
range of local services and facilities that support both existing and future residents. These include a
primary school, early years provision, convenience retail with post office, a health centre, library,
community facilities, and recreational spaces. The village is served by established and frequent bus
services to Longstanton and Bar Hill and onto Cambridge City Centre. The Site is partially previously
developed land and partially greenfield. Importantly, the Site is not located with the Cambridgeshire
Green Belt and as such should be sequentially allocated for development. Whilst the Site currently lies
outside the settlement framework, it neighbours existing development and would represent a logical
extension to the village whilst helping to meet the draft local plan’s significant housing requirements. The
Site is located wholly within Flood Zone 1. Any minimal surface water flooding can easily be designed out
through the development process There are no protected trees or priority habitats located within the Site.
There are no major heritage concerns with development of this Site. The Site does not lie within a
Conservation Area and is not in proximity to any listed buildings. There are no key infrastructure or
utilities running across the Site.
Development Proposals

The Site is submitted to deliver up to 125 dwellings. The Site is proposed to comprise both market and
affordable housing as well as accompanying uses such as public open space and biodiversity net gain. It
is anticipated that BNG would be provided in the southern portion of the site. The site relates well to the
existing built form of Willingham and represents a logical and sustainable opportunity for growth,
adjacent to established residential development. The land is well-defined by existing boundaries,
including Priest Lane and existing vegetation, which provide a clear and defensible edge to the
development parcel. Its scale and configuration allow for a sensitively designed scheme that can
integrate effectively with the surrounding context while delivering much-needed new homes. The village
benefits from a well-established and diverse range of local services and facilities that support both
existing and future residents. These include a primary school, early years provision, convenience retail
with post office, a health centre, library, community facilities, and recreational spaces. The village is
served by established and frequent bus services to Longstanton and Bar Hill and onto Cambridge City
Centre. The Site’s proximity to local services and transport options makes it a highly suitable and
deliverable location for development within the emerging local plan. The landowners have confirmed that
the Site is available for development in the next 0-5 years.
Access
An indicative vehicular access point is shown on the submitted location plan. Access to the Site is
proposed from the adopted highway off Priests Lane, providing a clear and well-defined point of entry
that integrates with the existing highway network and facilitates safe and efficient vehicular movements.

• Revise housing supply assumptions by removing unrealistic windfall, delivery and build-out
assumptions.
• Reduce reliance on a small number of large strategic sites with significant infrastructure
dependencies.
• Allocate additional small and medium-sized housing sites to improve deliverability and support
SME builders.
• Direct a greater proportion of growth to sustainable rural settlements and villages.
• Provide specific village housing allocations rather than relying primarily on windfall development.
• Create a more balanced distribution of growth across Greater Cambridge.
• Increase housing choice, flexibility and affordability by providing a wider range of site sizes and
locations.
• Use a more robust housing land supply approach and ensure sufficient delivery in the early
years of the plan.

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.
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.
II.
III.
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.
Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. Given this experience we are very concerned that the draft
strategy for the Plan (Policy S/DS) relies very heavily on allocating significant dwelling numbers on a
small number of very large sites. These sites rely on the timely provision of strategic scale infrastructure
which must be in place before these sites can be delivered.
The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (4,500 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway Travel Hub on the adjacent side of the
A505. The draft Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We
believe this is highly unlikely for the reasons set out in this representation.
The NPPF 2024 requires in paragraphs 61, 69 and 78 local plans to allocate additional housing land
where it cannot demonstrate an adequate housing supply. Paragraphs 72 to 77 encourage planning
authorities to identify a sufficient supply and mix of sites, support opportunities for large-scale
development, and make realistic assessments of delivery rates, including for strategic urban
extensions and new settlements. We do not believe these larger allocations will deliver until late in the
plan period leaving a hole in delivery in the early part the plan (as evidenced within the Housing Needs
and Matters Report). This hole needs to be filled with deliverable and sustainable sites where housing,
including affordable housing is needed. The NPPF 2024 at paragraph 73 recognises the importance of
smaller sites as they tend to be built more quickly, and allocating such sites will support small and
medium-sizes enterprise housebuilders.
Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that the chosen draft strategy approach sets the draft local plan on a path of over
reliance on these sites which is problematic for the following reasons:
The speed at which these developments can deliver homes is very often far slower than the Councils
have envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the large
strategic sites in the adopted Development Plan, may now be delivering at an appropriate rate, however
they came on stream years later than anticipated.
The Councils have not identified any new allocations for housing in the rural area which fails to support
the vitality of the rural area and existing settlements. We believe that this decision, has been made in
part, to avoid development in the Green Belt, and therefore fails to strike a more balanced approach to
housing delivery across the Plan period.
The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from the
settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest preference to
deliver jobs and homes, clearly fails to distinguish between what may be sustainable locations in the rural
area which is clearly capable of delivering an appropriate scale of development in the first half of the plan
period which is likely to experience a significant deficit due to the infrastructure required by the large
strategic sites allocated.
Policy S/SH effectively creates a juxtaposition whereby it is recognised that growth within Rural
Settlements need not be unduly constrained as it benefits from a reasonable level of services, facilities
and accessibility to the main urban area; yet in failing to allocate any sites, growth is basically
constrained to the settlement boundaries where windfall opportunities are restricted. Rural Settlements
benefitting from well-established and diverse range of local services and facilities that can support both
existing and future residents. These include schools, early years provision, convenience retail with post
office, a health centre, library, community facilities, and recreational spaces.
The focus upon large new settlements, urban redevelopment and SUEs fails to properly consider the
need to offer sufficient choice and flexibility to perspective homeowners. Not all prospective purchasers
will be able to, or wish to buy, in these locations whether due to affordability constraints, lifestyle
preferences, or housing type availability. It is therefore important to allocate housing sites in settlement
locations in order to deliver more affordable housing and a broader range of options for housing choice.
Figure 9 in the plan identifies only 15% of the housing allocation for this local plan in the rural area which
is the lowest amount for several decades and more needs to be made of the rural area option in this local
plan.
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 delver 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.

• Revise housing supply assumptions by removing unrealistic windfall, delivery and build-out
assumptions.
• Reduce reliance on a small number of large strategic sites with significant infrastructure
dependencies.
• Allocate additional small and medium-sized housing sites to improve deliverability and support
SME builders.
• Direct a greater proportion of growth to sustainable rural settlements and villages.
• Provide specific village housing allocations rather than relying primarily on windfall development.
• Create a more balanced distribution of growth across Greater Cambridge.
• Increase housing choice, flexibility and affordability by providing a wider range of site sizes and
locations.
• Use a more robust housing land supply approach and ensure sufficient delivery in the early
years of the plan.

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.
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.
II.
III.
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.
Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. Given this experience we are very concerned that the draft
strategy for the Plan (Policy S/DS) relies very heavily on allocating significant dwelling numbers on a
small number of very large sites. These sites rely on the timely provision of strategic scale infrastructure
which must be in place before these sites can be delivered.
The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (4,500 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway Travel Hub on the adjacent side of the
A505. The draft Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We
believe this is highly unlikely for the reasons set out in this representation.
The NPPF 2024 requires in paragraphs 61, 69 and 78 local plans to allocate additional housing land
where it cannot demonstrate an adequate housing supply. Paragraphs 72 to 77 encourage planning
authorities to identify a sufficient supply and mix of sites, support opportunities for large-scale
development, and make realistic assessments of delivery rates, including for strategic urban
extensions and new settlements. We do not believe these larger allocations will deliver until late in the
plan period leaving a hole in delivery in the early part the plan (as evidenced within the Housing Needs
and Matters Report). This hole needs to be filled with deliverable and sustainable sites where housing,
including affordable housing is needed. The NPPF 2024 at paragraph 73 recognises the importance of
smaller sites as they tend to be built more quickly, and allocating such sites will support small and
medium-sizes enterprise housebuilders.
Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that the chosen draft strategy approach sets the draft local plan on a path of over
reliance on these sites which is problematic for the following reasons:
The speed at which these developments can deliver homes is very often far slower than the Councils
have envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the large
strategic sites in the adopted Development Plan, may now be delivering at an appropriate rate, however
they came on stream years later than anticipated.
The Councils have not identified any new allocations for housing in the rural area which fails to support
the vitality of the rural area and existing settlements. We believe that this decision, has been made in
part, to avoid development in the Green Belt, and therefore fails to strike a more balanced approach to
housing delivery across the Plan period.
The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from the
settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest preference to
deliver jobs and homes, clearly fails to distinguish between what may be sustainable locations in the rural
area which is clearly capable of delivering an appropriate scale of development in the first half of the plan
period which is likely to experience a significant deficit due to the infrastructure required by the large
strategic sites allocated.
Policy S/SH effectively creates a juxtaposition whereby it is recognised that growth within Rural
Settlements need not be unduly constrained as it benefits from a reasonable level of services, facilities
and accessibility to the main urban area; yet in failing to allocate any sites, growth is basically
constrained to the settlement boundaries where windfall opportunities are restricted. Rural Settlements
benefitting from well-established and diverse range of local services and facilities that can support both
existing and future residents. These include schools, early years provision, convenience retail with post
office, a health centre, library, community facilities, and recreational spaces.
The focus upon large new settlements, urban redevelopment and SUEs fails to properly consider the
need to offer sufficient choice and flexibility to perspective homeowners. Not all prospective purchasers
will be able to, or wish to buy, in these locations whether due to affordability constraints, lifestyle
preferences, or housing type availability. It is therefore important to allocate housing sites in settlement
locations in order to deliver more affordable housing and a broader range of options for housing choice.
Figure 9 in the plan identifies only 15% of the housing allocation for this local plan in the rural area which
is the lowest amount for several decades and more needs to be made of the rural area option in this local
plan.
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 delver 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.

In order to overcome the issues highlighted in this representation and the enclosed Note on Housing
Need and Supply matters, and progress a sound Local Plan, it will be necessary to undertake the
following additional work and revise the proposed housing requirement accordingly:
• Increase the housing requirement to reflect as a minimum the minimum local housing need of
the standard method for 48,090 homes.
• Prepare housing projections which align with the economic ambitions set out in the recently
adopted Local Growth Plan, which the CPCA suggest will necessitate a requirement of at least
59,409 homes but potentially substantially more.
• Consider whether it would be sustainable to deliver a greater number of homes to better respond
to the acute need for affordable housing.
• In light of the available evidence, this will necessitate a requirement of at least 59,409 homes
over the plan period to support the local and national economy, rather than the proposed
insufficient housing requirement of 48,069 homes which falls short of meeting even the minimum
local housing need and pays no regard to the level of housing necessary to support the local and
national economy.
It is requested that the GCLP should allocate additional sites in Greater Cambridge to directly respond to
the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth
potential. The Site is available for allocation and can assist in delivering new housing development in a
sustainable way.

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.
II.
III.
IV.
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.
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.
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.
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 Proposed Submission 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 Local Growth Plan. 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
Employment and Housing Needs Update 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.