Greater Cambridge Local Plan: Proposed Submission

Policy S/JH should be modified to provide for a higher minimum housing requirement which properly reflects Greater Cambridge’s economic growth ambitions, committed and planned infrastructure investment, and the reasonable higher-growth outcomes identified in the Employment and Housing Evidence Update 2025.
The approach to neighbourhood housing requirements should also be amended to provide greater certainty that identified requirements can be met through planned housing provision. In particular, the Plan should not rely unduly on unidentified future sources of supply or windfall development to meet neighbourhood housing requirements, including the identified requirement for Girton.
Consequential amendments should be made to the Development Strategy and site allocations, where necessary, to ensure that both the increased overall housing requirement and identified neighbourhood housing requirements can be delivered through a sufficient supply of sustainable and deliverable housing land.

Wain Estates objects to Policy S/JH.

Growth Scenarios

Paragraph 69 of the December 2024 National Planning Policy Framework (“the Framework”) recognises that a housing requirement may need to exceed the Standard Method figure where this is justified by growth ambitions linked to economic development or infrastructure investment. Greater Cambridge is a nationally important growth area and Wain Estates considers that the Proposed Submission Local Plan does not sufficiently reflect the scale of that ambition.

This continues the objection made by Wain Estates at Regulation 18, namely that the Councils’ reliance on the central growth scenario is overly conservative and does not adequately reflect the growth potential of Greater Cambridge. Since Regulation 18, the case for planning for a higher level of growth has strengthened.

Policy S/JH identifies a minimum housing requirement of 48,069 homes over the 2024–2045 Plan period, equivalent to 2,289 dwellings per annum, alongside provision for 73,300 additional jobs. The Employment and Housing Evidence Update 2025 (“EHNU 2025”) adopts the central growth scenario as the preferred basis for the Plan, whilst also identifying higher-growth scenarios which place greater weight on the rapid growth experienced by Greater Cambridge’s key economic sectors. The Local Plan itself recognises that the continuing strength of the nationally important Greater Cambridge economy provides justification for exploring higher employment and related housing figures.

Calculations using the latest 2026 housing stock and affordability inputs reveals a Standard Method minimum of 2,290 homes per annum, or 48,090 homes over the Plan period. The CPCA’s position is that Cambridgeshire and Peterborough Combined Authority go further and note that to support economic growth, at least 59,409 homes should be planned for. These findings reinforce Wain Estates’ existing case for a more ambitious housing requirement.

The scale of the alternative growth outcomes is material. The EHNU 2025 identifies a Central scenario of approximately 73,200 additional jobs, equivalent to around 3,490 jobs per annum, with an associated housing need of 2,292 dwellings per annum under the preferred 2011 commuting assumptions.

By comparison, the High Sensitivity scenario identifies approximately 85,900 additional jobs and a housing need of 2,674 dwellings per annum, whilst the High scenario identifies approximately 90,900 additional jobs, equivalent to around 4,330 jobs per annum, with an associated housing need of 2,829 dwellings per annum. These figures should also be considered in the context of recorded employment growth of approximately 3,985 jobs per annum between 2010 and 2020. They demonstrate that higher-growth outcomes are credible alternatives which should not be discounted when determining the appropriate housing requirement.

The relationship between employment growth and housing need is fundamental. Greater employment growth generates additional demand for housing and, where sufficient housing is not provided close to employment opportunities, risks increasing affordability pressures and levels of in-commuting. The central scenario expressly incorporates assumptions of slower periods of growth, contraction and economic shocks and is therefore inherently cautious when considered against Greater Cambridge’s wider economic ambitions.

In June 2026, the Government confirmed that it would establish a Development Corporation for Greater Cambridge, building on the work of the Cambridge Growth Company to unlock and accelerate development and support infrastructure-first growth. Greater Cambridge has also continued to benefit from significant national, regional and local infrastructure investment, including Cambridge South Station, East West Rail, the Cambourne to Cambridge scheme (which has recently received approval for Transport and Works Act Order in September 2026) and Cambridge South East Transport.

These interventions reinforce Cambridge’s position as an area of national economic importance capable of supporting higher growth. This is particularly relevant given that the EHNU 2025 itself acknowledges that higher-growth scenarios could be achieved where there is a step change in infrastructure investment and development.

The December 2024 Framework provides the relevant national policy basis against which the Local Plan will be examined. It recognises circumstances in which housing provision may appropriately exceed identified local housing need where this reflects economic growth or infrastructure investment ambitions. The August 2026 Framework further reinforces this direction of national policy through Policy HO2. Whilst the soundness of the Greater Cambridge Local Plan will be assessed against the December 2024 Framework, the current national policy position reinforces the continuing emphasis on growth and the particular economic importance of Greater Cambridge.

In this context, Wain Estates considers that Policy S/JH should plan for a more ambitious level of housing growth and should not constrain the ability of the Development Strategy to respond to higher-growth outcomes. This could most easily be achieved through the allocation of small and medium sized sites which are deliverable within the first 10 years of the plan period. Providing additional housing in sustainable locations would support Greater Cambridge’s economic growth, help address affordability pressures and assist in reducing the need for longer-distance commuting.

Planning for a higher level of housing growth would also have consequential implications for the spatial strategy and site allocations. A broader portfolio of sustainable and deliverable housing sites would be required to ensure that increased housing provision can be delivered throughout the Plan period. Land at Girton Road, Girton (Site ID 115170), promoted by Wain Estates, represents one such opportunity, with the detailed case for its allocation addressed in Wain Estates’ representation to Policy S/DS and S/RRA.

Neighbourhood Housing Requirements

Policy S/JH also establishes housing requirements for designated neighbourhood areas, with the detailed requirements set out in Appendix C. The Proposed Submission Plan identifies a housing requirement of 88 homes for the Girton neighbourhood area for the period 2025–2045. Notwithstanding this identified requirement, no specific housing allocation is proposed at Girton to assist in securing its delivery.

Appendix C explains that, once actual completions in 2024/25 and allocations in sustainable locations have been taken into account, a residual requirement of 6,183 homes remains to be met from other sources or through windfall sites. Neighbourhood housing requirements are then calculated by distributing this residual requirement according to each neighbourhood area’s share of the Greater Cambridge population.

Wain Estates remains concerned that this approach places significant reliance upon windfall development and other unidentified opportunities coming forward over the Plan period. This concern was raised at Regulation 18 with reference to the Greater Cambridge Housing Delivery Study Addendum (October 2025) . At that stage, Wain Estates noted that, whilst the evidence supported a windfall allowance of 425 dwellings per annum, average windfall delivery over the latest seven years of the dataset was approximately 395 dwellings per annum, below the allowance relied upon.

The Greater Cambridge Housing Delivery Study Addendum Update (2026) considers the concerns raised at Regulation 18 regarding declining recent windfall delivery. However, it does not materially revise the approach.

AECOM continues to rely on historic delivery between 2006 and 2024 retaining a windfall allowance of 425 dwellings per annum. Whilst the Update acknowledges lower delivery in recent years, including 2020/21 and 2023/24, it concludes that the longer-term evidence justifies retaining the allowance. Wain Estates remains concerned that this does not adequately address the more recent delivery trend identified at Regulation 18 and that greater certainty should be secured through planned allocations.

Wain Estates does not seek to dispute that windfall development will make an important contribution to housing supply. However, the scale of reliance upon unidentified future sites provides less certainty than specific planned allocations, particularly where neighbourhood housing requirements are themselves calculated from a residual requirement which is expected to be met from other sources or windfalls.

Greater certainty should therefore be provided through the allocation of sustainable and deliverable sites.

This concern is particularly relevant at Girton. Land at Girton Road, Girton (Site ID 115170) has been promoted for approximately 75 homes, representing a substantial proportion of the neighbourhood area’s identified requirement of 88 homes. The site has been promoted throughout the Local Plan process and provides an opportunity to secure planned housing delivery at a designated Minor Rural Centre with good access to services, employment and sustainable transport, including connections to Cambridge, West Cambridge and Eddington, rather than relying predominantly upon unidentified future opportunities.

The neighbourhood housing requirement therefore reinforces the case for the spatial strategy to identify sufficient sustainable and deliverable allocations to provide greater certainty of delivery. The detailed sustainability, deliverability and site-specific case for the allocation of Land at Girton Road is addressed further in Wain Estates’ representation to Policy S/DS and S/RRA.

Conclusion

For these reasons, Wain Estates considers that Policy S/JH is not positively prepared or justified and is not consistent with national policy.

The proposed housing requirement does not adequately respond to Greater Cambridge’s exceptional economic circumstances, the Government’s growth ambitions and the scale of committed and planned infrastructure investment. The higher-growth scenarios identified in the Councils’ own evidence represent credible alternative outcomes and should be given greater weight in determining the appropriate housing requirement.

At the same time, the neighbourhood requirement approach does not provide sufficient certainty of planned delivery at Girton. Policy S/JH should therefore provide for a more ambitious housing requirement, with consequential amendments to the Development Strategy, site allocations and Appendix C to ensure sufficient sustainable and deliverable housing land.

Policy S/DS should be modified to provide a more balanced and diversified distribution of housing growth, including a greater role for sustainable Rural Centres and Minor Rural Centres and a wider portfolio of small and medium-sized sites capable of contributing throughout the Plan period.

Additional sustainable and deliverable sites identified through the Call for Sites process should be allocated in order to reduce delivery risk and reliance upon unidentified windfall development. This should include the allocation of Land at Girton Road, Girton (Site ID 115170) for approximately 75 homes.

Wain Estates objects to Policy S/DS.

Development Strategy and Delivery of Strategic Sites

The Development Strategy continues to place substantial reliance upon a relatively small number of large strategic sites to accommodate housing growth. Wain Estates does not object to strategic-scale development forming an important component of the Local Plan. The objection concerns the degree of reliance placed upon large and infrastructure-dependent sites without a sufficiently diverse portfolio of smaller and medium-sized sites capable of contributing throughout the Plan period. The location of strategic allocations has been primarily selected because they lie outside of the Green Belt. This has resulted in a strategy which does not represent the most sustainable option among the realistic alternatives as it fails to recognise where sustainable alternatives within the Green Belt exist. Sustainable sites within the Green Belt appear to have been discounted solely due to their designation, to the detriment of delivering an effective and sustainable pattern of development including a mix of site location and sizes which is able to provide a more diversified housing stock to meet the needs of the District across the full plan period.

This concern was raised at Regulation 18 where a review of strategic housing sites found an average delay of approximately 4.9 years between the Councils first anticipated housing completions and actual first delivery. Data from A review of the latest trajectory for Northstowe, Cambridge East (Airport) and Waterbeach New Town finds that even when assuming delivery equivalent to the strongest comparator, there will be a shortfall of 3,581 homes over the Plan period than assumed by the Councils.

The Proposed Submission Plan does not remove this delivery concern. In particular, Cambourne North is proposed for approximately 13,000 homes, of which 2,550 homes are anticipated within the Plan period. Development is identified as commencing from 2034, subject to the necessary water infrastructure being available, and the Plan identifies the East West Rail station and Cambourne-to-Cambridge high-quality public transport corridor as central to its accessibility.

Similarly, Grange Farm is proposed for approximately 4,500 homes, with 2,550 homes by 2045, again subject to necessary water infrastructure being available. The policy also states that the new settlement will play a critical role in extending the Cambridge South East Transport (CSET) scheme.

The Plan identifies a total housing supply of 52,032 homes against the requirement for 48,069 homes, providing 8.2% headroom. However, aggregate headroom does not address the timing or distribution of delivery. Windfall rates should not form part of the specific deliverable supply for the first five years, and strategic site delivery rates have been shown to be much slower than estimated. Therefore, the number of homes which will be built within the plan-period is significantly lower, with a supply of approximately 4.41 years using the Liverpool method and 4.06 years using Sedgefield. This reinforces the importance of identifying additional deliverable sites capable of contributing while the larger strategic allocations and their supporting infrastructure are progressed.

The Plan expressly acknowledges that sustained annual completions at or above the housing requirement are not anticipated until the second half of the Plan period, owing to the chosen development strategy and water and transport infrastructure constraints. It relies upon this position to justify use of the Liverpool methodology for calculating five-year housing land supply.

A more diversified portfolio of sustainable and deliverable sites would therefore reduce delivery risk and provide a more continuous supply of housing throughout the Plan period.

Distribution of Growth in the Rural Area

At Regulation 18, Wain Estates criticised the absence of new rural housing allocations. It is acknowledged that the Proposed Submission Plan now includes a number of allocations within the rural area, and this change is welcomed. However, the underlying concern remains.

The strategy continues to direct the principal scale of growth towards Cambridge, the edge of Cambridge and new settlements, with a more limited role for existing rural settlements. The Plan itself confirms that the rural area will have a lower share of development under the new strategy.

The scale of the Plan's reliance on strategic growth locations is illustrated by Table 4, which directs 30% of housing development to the edge of Cambridge and a further 44% to new settlements. Together, these locations account for 74% of planned housing growth, compared with 15% in the Rural Area.

Wain Estates considers that a stronger role should be provided for sustainable Rural Centres and Minor Rural Centres.

Furthermore, Wain Estates consider that sustainability credentials of individual rural settlements vary considerably and development in the Rural Area should not be treated as collectively less sustainable.

This is particularly relevant to Girton, a designated Minor Rural Centre with a close functional relationship with Cambridge. Its proximity to West Cambridge and Eddington, together with existing bus and cycle connections, demonstrates that appropriately located housing in the Rural Area need not result in excessive reliance upon the private car. Planned growth at such locations can provide homes close to major employment opportunities while supporting existing village services and allowing households to remain close to established family and community networks.

Small and Medium-Sized Sites

A more balanced Development Strategy should provide a stronger role for small and medium-sized housing sites. Paragraph 73 of the December 2024 NPPF recognises the important contribution such sites can make to meeting housing requirements. Small and medium-sized sites can broaden the range of development opportunities, support SME housebuilders and, in many cases, progress without the scale of infrastructure and lead-in periods associated with strategic development.

Wain Estates remains concerned that the Proposed Submission Plan does not provide a sufficiently diverse portfolio of specifically allocated non-strategic sites. The Plan anticipates approximately 6,660 homes from windfall development - around 14% of the 48,069-home minimum requirement - alongside substantial reliance on strategic allocations. Unidentified future opportunities do not provide the same degree of certainty as planned allocations.
At Regulation 18, Wain Estates highlighted that the historic windfall evidence showed a more recent delivery rate below the proposed allowance, including a seven-year average of approximately 395 dwellings per annum, compared with the assumed 425 dwellings per annum.

The Housing Delivery Study Addendum Update (2026) has reconsidered the representations made on windfall delivery but continues to support an allowance of 425 dwellings per annum, using the longer-term 2006–2024 evidence base. The updated evidence therefore does not remove Wain Estates' underlying concern about placing substantial reliance upon unidentified future opportunities.

Windfall development will undoubtedly make an important contribution to housing supply, but it does not provide the same certainty as planned allocations. Opportunities for brownfield redevelopment and residential subdivision are finite, and a stronger portfolio of allocated small and medium-sized sites would provide greater certainty for delivery and investment.

Land at Girton Road is a medium-sized, non-strategic site capable of contributing to a more diverse and balanced housing supply. Its allocation would complement the Local Plan's larger strategic sites by providing a deliverable opportunity with shorter lead-in times and fewer strategic infrastructure dependencies, thereby providing development within the first 5-10 years of the Plan period as required by Paragraph 72 of the Framework.

Housing Choice and Existing Communities

A strategy concentrated on large strategic developments also narrows the range of locations available to households. Not all households will choose, or be able, to meet their needs in new settlements; some need homes close to existing family, services and employment, and insufficient planned provision in established villages can generate additional travel.

An appropriate level of planned growth at sustainable existing settlements can also support the vitality of local shops, schools, services and facilities. Paragraph 83 of the December 2024 NPPF states that, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities, and that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. A genuinely diversified strategy should therefore provide housing across a range of locations and site sizes, rather than relying principally upon new settlements and strategic extensions.

Girton's Housing Requirement

The case for a more balanced distribution is reinforced by the housing requirement identified for the Girton neighbourhood area. Appendix C of the Proposed Submission Plan identifies a requirement for 88 homes at Girton for 2025–2045, yet no specific housing allocation is made at the settlement.

The approach therefore relies upon windfall development, exception sites and other unidentified opportunities. Within the defined development extent of Minor Rural Centres, windfall housing is generally subject to an indicative maximum of 30 dwellings. Paragraph 2.115 expressly confirms that this guideline does not apply to allocations, which can exceed it.

Reliance upon smaller windfall development can also reduce certainty regarding affordable housing. Policy H/AH applies affordable housing requirements to major residential developments, defined as development of 10 or more homes, or on sites of 0.5 hectares or more. Smaller schemes of 1–9 dwellings on sites below 0.5 hectares would therefore fall below that threshold.

Land at Girton Road could provide approximately 75 homes, including affordable housing, through a plan-led allocation. If allocated, Appendix C should be consequentially amended, providing materially greater certainty than reliance on unidentified future sites.

The site is well related to Girton's services and to employment at West Cambridge and Eddington, and Wain Estates' evidence identifies it as available now and capable of delivering homes within five years, a stance echoed by the HELAA, 2026. At this scale it can make a meaningful contribution without the lead-in periods and strategic infrastructure requirements of the largest allocations, complementing rather than replacing them.

Conclusion

For these reasons, Wain Estates considers that Policy S/DS is not justified or effective.
The Proposed Submission Plan continues to rely substantially upon large strategic sites whose delivery is dependent upon significant infrastructure and whose contribution is weighted towards the later part of the Plan period. This risk is expressly reflected in the Plan's acknowledgement that sustained delivery at or above the housing requirement is not anticipated until the second half of the Plan period.

At the same time, the strategy affords a comparatively limited role to sustainable existing rural settlements and relies substantially upon unidentified windfall development to supplement the portfolio of specifically identified small and medium-sized sites.

A more balanced Development Strategy should therefore:

• provide a greater role for sustainable Rural Centres and Minor Rural Centres;
• identify a wider portfolio of small and medium-sized, non-strategic housing sites capable of contributing earlier and throughout the Plan period;
• reduce reliance upon unidentified windfall development; and
• provide greater housing choice and certainty of delivery while strategic sites and associated infrastructure are brought forward.

Land at Girton Road, Girton (Site ID 115170) represents such an opportunity. Its allocation for approximately 75 homes would diversify the housing land portfolio, provide planned and comparatively early delivery at a sustainable Minor Rural Centre, include affordable housing, and respond directly to the residual local housing need evidenced by Girton's 88-home neighbourhood requirement.

Policy S/RRA should be modified to include green belt release and allocation of Land at Girton Road, Girton (Site ID 115170) as a residential allocation for approximately 75 homes, including affordable housing, together with associated open space, landscaping, drainage and sustainable transport connections.

Consequential amendments should be made to the Policies Map and, where necessary, Policy S/GB to facilitate the allocation.

The allocation should be supported by site-specific requirements securing a landscape-led form of development which responds to the scale and character of Girton, retains and reinforces existing trees and hedgerows, provides a strong landscaped boundary to the remaining Green Belt and delivers safe pedestrian and cycle connections to the existing settlement and wider sustainable transport network.

This modification would provide planned housing delivery at a sustainable Minor Rural Centre, make a substantial contribution towards Girton’s identified neighbourhood housing requirement and broaden the range of sites available to deliver housing over the Plan period.

Wain Estates objects to Policy S/RRA

Sustainability of Girton and Site Omission

The Proposed Submission Plan recognises that rural villages should continue to thrive and sustain their local services. The supporting text to the Rest of the Rural Area policies states that development is proposed in and around villages which have good transport links and services, while seeking to avoid directing substantial growth to locations where travel by private car is the easiest or only realistic means of transport.

Wain Estates supports that principle, but its application must recognise the substantial variation in sustainability between rural settlements. Girton is a Minor Rural Centre, which the Plan describes as having a greater level of services, facilities and employment than most other settlements and as an accessible hub serving everyday needs and a wider rural hinterland.

The location of the proposed allocations has been primarily selected because they lie outside of the Green Belt, failing to recognise where sustainable alternatives within the Green Belt exist. Sustainable sites within the Green Belt appear to have been discounted solely due to their designation, to the detriment of delivering an effective and sustainable pattern of development including a mix of site location and sizes which is able to provide a more diversified housing stock to meet the needs of the District across the full plan period.

The Plan's own allocations demonstrate that Minor Rural Centres are not bound by a 30-home ceiling on planned growth. It allocates 125 homes at Melbourn, also a Minor Rural Centre, noting its relationship with Melbourn Science Park and active travel connections. Paragraph 2.115 also expressly confirms that indicative scheme-size guidelines do not apply to Local Plan allocations.

Girton's location reinforces that case. It sits immediately north-west of Cambridge and has strong links to West Cambridge and Eddington. The Site Vision identifies a GP surgery and convenience store approximately two minutes' walk away, Girton Glebe Primary School approximately 550 metres from the site, National Cycle Route 24 along Girton Road and bus stops approximately 200 metres away served by the No. 6 service to Cambridge. These characteristics distinguish Girton from less accessible rural locations and demonstrate that housing here need not result in unacceptable car reliance.

Despite these sustainability credentials, no housing allocation is proposed at Girton. Appendix C identifies an 88-home requirement for 2025-2045, evidencing residual local housing need. Land at Girton Road could provide approximately 75 homes through plan-led development; if allocated, Appendix C should be consequentially updated rather than leaving that need to unidentified future opportunities. Land at Girton Road has been promoted through the Local Plan process and is supported by a Site Vision demonstrating how residential development could be sensitively accommodated. The proposed development would provide around 75 homes, including affordable housing, together with public open space and landscape enhancement. The site is available and capable of delivering new homes within five years.

The site's landscape and Green Belt context has also been considered through the Bidwells Green Belt Study. The Study concludes that the site qualifies as Grey Belt under the NPPF definition, on the basis that it does not contribute strongly to Green Belt purposes (a), (b) or (d) and is not subject to any of the relevant footnote 7 designations. In particular, it finds that development would retain a considerable landscape gap between Girton and Histon and would not undermine the purposes of the adjoining Green Belt. The Study also identifies existing tree belts around the site which provide visual containment and opportunities for reinforcement. It recommends that development responds to the scale and built form of Girton, strengthens perimeter planting, maintains a clear distinction from the remaining Green Belt and preserves the compact form of the settlement. These principles are reflected in the Illustrative Framework Plan and demonstrate that a landscape-led scheme could respond appropriately to the site's rural-edge context.

Wain Estates therefore considers that the omission of Land at Girton Road from Policy S/RRA represents a missed opportunity to plan growth at a sustainable Minor Rural Centre. Its allocation would broaden the housing portfolio, respond to identified local need, support existing services and provide homes within sustainable travelling distance of Cambridge's principal employment areas.

Policy S/RRA should therefore be modified to allocate Land at Girton Road, Girton (Site ID 115170) for approximately 75 homes.

Additional sustainable and deliverable sites identified through the Call for Sites process should be allocated in order to reduce delivery risk and reliance upon unidentified windfall development. This should include the allocation of Land at Girton Road, Girton (Site ID 115170) for approximately 75 homes.

Wain Estates objects to Policy S/DS.

Development Strategy and Delivery of Strategic Sites

The Development Strategy continues to place substantial reliance upon a relatively small number of large strategic sites to accommodate housing growth. Wain Estates does not object to strategic-scale development forming an important component of the Local Plan. The objection concerns the degree of reliance placed upon large and infrastructure-dependent sites without a sufficiently diverse portfolio of smaller and medium-sized sites capable of contributing throughout the Plan period. The location of strategic allocations has been primarily selected because they lie outside of the Green Belt. This has resulted in a strategy which does not represent the most sustainable option among the realistic alternatives as it fails to recognise where sustainable alternatives within the Green Belt exist. Sustainable sites within the Green Belt appear to have been discounted solely due to their designation, to the detriment of delivering an effective and sustainable pattern of development including a mix of site location and sizes which is able to provide a more diversified housing stock to meet the needs of the District across the full plan period.

This concern was raised at Regulation 18 where a review of strategic housing sites found an average delay of approximately 4.9 years between the Councils first anticipated housing completions and actual first delivery. Data from A review of the latest trajectory for Northstowe, Cambridge East (Airport) and Waterbeach New Town finds that even when assuming delivery equivalent to the strongest comparator, there will be a shortfall of 3,581 homes over the Plan period than assumed by the Councils.

The Proposed Submission Plan does not remove this delivery concern. In particular, Cambourne North is proposed for approximately 13,000 homes, of which 2,550 homes are anticipated within the Plan period. Development is identified as commencing from 2034, subject to the necessary water infrastructure being available, and the Plan identifies the East West Rail station and Cambourne-to-Cambridge high-quality public transport corridor as central to its accessibility.

Similarly, Grange Farm is proposed for approximately 4,500 homes, with 2,550 homes by 2045, again subject to necessary water infrastructure being available. The policy also states that the new settlement will play a critical role in extending the Cambridge South East Transport (CSET) scheme.

The Plan identifies a total housing supply of 52,032 homes against the requirement for 48,069 homes, providing 8.2% headroom. However, aggregate headroom does not address the timing or distribution of delivery. Windfall rates should not form part of the specific deliverable supply for the first five years, and strategic site delivery rates have been shown to be much slower than estimated. Therefore, the number of homes which will be built within the plan-period is significantly lower, with a supply of approximately 4.41 years using the Liverpool method and 4.06 years using Sedgefield. This reinforces the importance of identifying additional deliverable sites capable of contributing while the larger strategic allocations and their supporting infrastructure are progressed.

The Plan expressly acknowledges that sustained annual completions at or above the housing requirement are not anticipated until the second half of the Plan period, owing to the chosen development strategy and water and transport infrastructure constraints. It relies upon this position to justify use of the Liverpool methodology for calculating five-year housing land supply.

A more diversified portfolio of sustainable and deliverable sites would therefore reduce delivery risk and provide a more continuous supply of housing throughout the Plan period.

Distribution of Growth in the Rural Area

At Regulation 18, Wain Estates criticised the absence of new rural housing allocations. It is acknowledged that the Proposed Submission Plan now includes a number of allocations within the rural area, and this change is welcomed. However, the underlying concern remains.

The strategy continues to direct the principal scale of growth towards Cambridge, the edge of Cambridge and new settlements, with a more limited role for existing rural settlements. The Plan itself confirms that the rural area will have a lower share of development under the new strategy.

The scale of the Plan's reliance on strategic growth locations is illustrated by Table 4, which directs 30% of housing development to the edge of Cambridge and a further 44% to new settlements. Together, these locations account for 74% of planned housing growth, compared with 15% in the Rural Area.

Wain Estates considers that a stronger role should be provided for sustainable Rural Centres and Minor Rural Centres.

Furthermore, Wain Estates consider that sustainability credentials of individual rural settlements vary considerably and development in the Rural Area should not be treated as collectively less sustainable.

This is particularly relevant to Girton, a designated Minor Rural Centre with a close functional relationship with Cambridge. Its proximity to West Cambridge and Eddington, together with existing bus and cycle connections, demonstrates that appropriately located housing in the Rural Area need not result in excessive reliance upon the private car. Planned growth at such locations can provide homes close to major employment opportunities while supporting existing village services and allowing households to remain close to established family and community networks.

Small and Medium-Sized Sites

A more balanced Development Strategy should provide a stronger role for small and medium-sized housing sites. Paragraph 73 of the December 2024 NPPF recognises the important contribution such sites can make to meeting housing requirements. Small and medium-sized sites can broaden the range of development opportunities, support SME housebuilders and, in many cases, progress without the scale of infrastructure and lead-in periods associated with strategic development.

Wain Estates remains concerned that the Proposed Submission Plan does not provide a sufficiently diverse portfolio of specifically allocated non-strategic sites. The Plan anticipates approximately 6,660 homes from windfall development - around 14% of the 48,069-home minimum requirement - alongside substantial reliance on strategic allocations. Unidentified future opportunities do not provide the same degree of certainty as planned allocations.
At Regulation 18, Wain Estates highlighted that the historic windfall evidence showed a more recent delivery rate below the proposed allowance, including a seven-year average of approximately 395 dwellings per annum, compared with the assumed 425 dwellings per annum.

The Housing Delivery Study Addendum Update (2026) has reconsidered the representations made on windfall delivery but continues to support an allowance of 425 dwellings per annum, using the longer-term 2006–2024 evidence base. The updated evidence therefore does not remove Wain Estates' underlying concern about placing substantial reliance upon unidentified future opportunities.

Windfall development will undoubtedly make an important contribution to housing supply, but it does not provide the same certainty as planned allocations. Opportunities for brownfield redevelopment and residential subdivision are finite, and a stronger portfolio of allocated small and medium-sized sites would provide greater certainty for delivery and investment.

Land at Girton Road is a medium-sized, non-strategic site capable of contributing to a more diverse and balanced housing supply. Its allocation would complement the Local Plan's larger strategic sites by providing a deliverable opportunity with shorter lead-in times and fewer strategic infrastructure dependencies, thereby providing development within the first 5-10 years of the Plan period as required by Paragraph 72 of the Framework.

Housing Choice and Existing Communities

A strategy concentrated on large strategic developments also narrows the range of locations available to households. Not all households will choose, or be able, to meet their needs in new settlements; some need homes close to existing family, services and employment, and insufficient planned provision in established villages can generate additional travel.

An appropriate level of planned growth at sustainable existing settlements can also support the vitality of local shops, schools, services and facilities. Paragraph 83 of the December 2024 NPPF states that, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities, and that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. A genuinely diversified strategy should therefore provide housing across a range of locations and site sizes, rather than relying principally upon new settlements and strategic extensions.

Girton's Housing Requirement

The case for a more balanced distribution is reinforced by the housing requirement identified for the Girton neighbourhood area. Appendix C of the Proposed Submission Plan identifies a requirement for 88 homes at Girton for 2025–2045, yet no specific housing allocation is made at the settlement.

The approach therefore relies upon windfall development, exception sites and other unidentified opportunities. Within the defined development extent of Minor Rural Centres, windfall housing is generally subject to an indicative maximum of 30 dwellings. Paragraph 2.115 expressly confirms that this guideline does not apply to allocations, which can exceed it.

Reliance upon smaller windfall development can also reduce certainty regarding affordable housing. Policy H/AH applies affordable housing requirements to major residential developments, defined as development of 10 or more homes, or on sites of 0.5 hectares or more. Smaller schemes of 1–9 dwellings on sites below 0.5 hectares would therefore fall below that threshold.

Land at Girton Road could provide approximately 75 homes, including affordable housing, through a plan-led allocation. If allocated, Appendix C should be consequentially amended, providing materially greater certainty than reliance on unidentified future sites.

The site is well related to Girton's services and to employment at West Cambridge and Eddington, and Wain Estates' evidence identifies it as available now and capable of delivering homes within five years, a stance echoed by the HELAA, 2026. At this scale it can make a meaningful contribution without the lead-in periods and strategic infrastructure requirements of the largest allocations, complementing rather than replacing them.

Conclusion

For these reasons, Wain Estates considers that Policy S/DS is not justified or effective.
The Proposed Submission Plan continues to rely substantially upon large strategic sites whose delivery is dependent upon significant infrastructure and whose contribution is weighted towards the later part of the Plan period. This risk is expressly reflected in the Plan's acknowledgement that sustained delivery at or above the housing requirement is not anticipated until the second half of the Plan period.

At the same time, the strategy affords a comparatively limited role to sustainable existing rural settlements and relies substantially upon unidentified windfall development to supplement the portfolio of specifically identified small and medium-sized sites.

A more balanced Development Strategy should therefore:

• provide a greater role for sustainable Rural Centres and Minor Rural Centres;
• identify a wider portfolio of small and medium-sized, non-strategic housing sites capable of contributing earlier and throughout the Plan period;
• reduce reliance upon unidentified windfall development; and
• provide greater housing choice and certainty of delivery while strategic sites and associated infrastructure are brought forward.

Land at Girton Road, Girton (Site ID 115170) represents such an opportunity. Its allocation for approximately 75 homes would diversify the housing land portfolio, provide planned and comparatively early delivery at a sustainable Minor Rural Centre, include affordable housing, and respond directly to the residual local housing need evidenced by Girton's 88-home neighbourhood requirement.

Review 5YHLS in context of comments.

Wain Estates objects to Policy S/DS.

Development Strategy and Delivery of Strategic Sites

The Development Strategy continues to place substantial reliance upon a relatively small number of large strategic sites to accommodate housing growth. Wain Estates does not object to strategic-scale development forming an important component of the Local Plan. The objection concerns the degree of reliance placed upon large and infrastructure-dependent sites without a sufficiently diverse portfolio of smaller and medium-sized sites capable of contributing throughout the Plan period. The location of strategic allocations has been primarily selected because they lie outside of the Green Belt. This has resulted in a strategy which does not represent the most sustainable option among the realistic alternatives as it fails to recognise where sustainable alternatives within the Green Belt exist. Sustainable sites within the Green Belt appear to have been discounted solely due to their designation, to the detriment of delivering an effective and sustainable pattern of development including a mix of site location and sizes which is able to provide a more diversified housing stock to meet the needs of the District across the full plan period.

This concern was raised at Regulation 18 where a review of strategic housing sites found an average delay of approximately 4.9 years between the Councils first anticipated housing completions and actual first delivery. Data from A review of the latest trajectory for Northstowe, Cambridge East (Airport) and Waterbeach New Town finds that even when assuming delivery equivalent to the strongest comparator, there will be a shortfall of 3,581 homes over the Plan period than assumed by the Councils.

The Proposed Submission Plan does not remove this delivery concern. In particular, Cambourne North is proposed for approximately 13,000 homes, of which 2,550 homes are anticipated within the Plan period. Development is identified as commencing from 2034, subject to the necessary water infrastructure being available, and the Plan identifies the East West Rail station and Cambourne-to-Cambridge high-quality public transport corridor as central to its accessibility.

Similarly, Grange Farm is proposed for approximately 4,500 homes, with 2,550 homes by 2045, again subject to necessary water infrastructure being available. The policy also states that the new settlement will play a critical role in extending the Cambridge South East Transport (CSET) scheme.

The Plan identifies a total housing supply of 52,032 homes against the requirement for 48,069 homes, providing 8.2% headroom. However, aggregate headroom does not address the timing or distribution of delivery. Windfall rates should not form part of the specific deliverable supply for the first five years, and strategic site delivery rates have been shown to be much slower than estimated. Therefore, the number of homes which will be built within the plan-period is significantly lower, with a supply of approximately 4.41 years using the Liverpool method and 4.06 years using Sedgefield. This reinforces the importance of identifying additional deliverable sites capable of contributing while the larger strategic allocations and their supporting infrastructure are progressed.

The Plan expressly acknowledges that sustained annual completions at or above the housing requirement are not anticipated until the second half of the Plan period, owing to the chosen development strategy and water and transport infrastructure constraints. It relies upon this position to justify use of the Liverpool methodology for calculating five-year housing land supply.

A more diversified portfolio of sustainable and deliverable sites would therefore reduce delivery risk and provide a more continuous supply of housing throughout the Plan period.

Distribution of Growth in the Rural Area

At Regulation 18, Wain Estates criticised the absence of new rural housing allocations. It is acknowledged that the Proposed Submission Plan now includes a number of allocations within the rural area, and this change is welcomed. However, the underlying concern remains.

The strategy continues to direct the principal scale of growth towards Cambridge, the edge of Cambridge and new settlements, with a more limited role for existing rural settlements. The Plan itself confirms that the rural area will have a lower share of development under the new strategy.

The scale of the Plan's reliance on strategic growth locations is illustrated by Table 4, which directs 30% of housing development to the edge of Cambridge and a further 44% to new settlements. Together, these locations account for 74% of planned housing growth, compared with 15% in the Rural Area.

Wain Estates considers that a stronger role should be provided for sustainable Rural Centres and Minor Rural Centres.

Furthermore, Wain Estates consider that sustainability credentials of individual rural settlements vary considerably and development in the Rural Area should not be treated as collectively less sustainable.

This is particularly relevant to Girton, a designated Minor Rural Centre with a close functional relationship with Cambridge. Its proximity to West Cambridge and Eddington, together with existing bus and cycle connections, demonstrates that appropriately located housing in the Rural Area need not result in excessive reliance upon the private car. Planned growth at such locations can provide homes close to major employment opportunities while supporting existing village services and allowing households to remain close to established family and community networks.

Small and Medium-Sized Sites

A more balanced Development Strategy should provide a stronger role for small and medium-sized housing sites. Paragraph 73 of the December 2024 NPPF recognises the important contribution such sites can make to meeting housing requirements. Small and medium-sized sites can broaden the range of development opportunities, support SME housebuilders and, in many cases, progress without the scale of infrastructure and lead-in periods associated with strategic development.

Wain Estates remains concerned that the Proposed Submission Plan does not provide a sufficiently diverse portfolio of specifically allocated non-strategic sites. The Plan anticipates approximately 6,660 homes from windfall development - around 14% of the 48,069-home minimum requirement - alongside substantial reliance on strategic allocations. Unidentified future opportunities do not provide the same degree of certainty as planned allocations.
At Regulation 18, Wain Estates highlighted that the historic windfall evidence showed a more recent delivery rate below the proposed allowance, including a seven-year average of approximately 395 dwellings per annum, compared with the assumed 425 dwellings per annum.

The Housing Delivery Study Addendum Update (2026) has reconsidered the representations made on windfall delivery but continues to support an allowance of 425 dwellings per annum, using the longer-term 2006–2024 evidence base. The updated evidence therefore does not remove Wain Estates' underlying concern about placing substantial reliance upon unidentified future opportunities.

Windfall development will undoubtedly make an important contribution to housing supply, but it does not provide the same certainty as planned allocations. Opportunities for brownfield redevelopment and residential subdivision are finite, and a stronger portfolio of allocated small and medium-sized sites would provide greater certainty for delivery and investment.

Land at Girton Road is a medium-sized, non-strategic site capable of contributing to a more diverse and balanced housing supply. Its allocation would complement the Local Plan's larger strategic sites by providing a deliverable opportunity with shorter lead-in times and fewer strategic infrastructure dependencies, thereby providing development within the first 5-10 years of the Plan period as required by Paragraph 72 of the Framework.

Housing Choice and Existing Communities

A strategy concentrated on large strategic developments also narrows the range of locations available to households. Not all households will choose, or be able, to meet their needs in new settlements; some need homes close to existing family, services and employment, and insufficient planned provision in established villages can generate additional travel.

An appropriate level of planned growth at sustainable existing settlements can also support the vitality of local shops, schools, services and facilities. Paragraph 83 of the December 2024 NPPF states that, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities, and that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. A genuinely diversified strategy should therefore provide housing across a range of locations and site sizes, rather than relying principally upon new settlements and strategic extensions.

Girton's Housing Requirement

The case for a more balanced distribution is reinforced by the housing requirement identified for the Girton neighbourhood area. Appendix C of the Proposed Submission Plan identifies a requirement for 88 homes at Girton for 2025–2045, yet no specific housing allocation is made at the settlement.

The approach therefore relies upon windfall development, exception sites and other unidentified opportunities. Within the defined development extent of Minor Rural Centres, windfall housing is generally subject to an indicative maximum of 30 dwellings. Paragraph 2.115 expressly confirms that this guideline does not apply to allocations, which can exceed it.

Reliance upon smaller windfall development can also reduce certainty regarding affordable housing. Policy H/AH applies affordable housing requirements to major residential developments, defined as development of 10 or more homes, or on sites of 0.5 hectares or more. Smaller schemes of 1–9 dwellings on sites below 0.5 hectares would therefore fall below that threshold.

Land at Girton Road could provide approximately 75 homes, including affordable housing, through a plan-led allocation. If allocated, Appendix C should be consequentially amended, providing materially greater certainty than reliance on unidentified future sites.

The site is well related to Girton's services and to employment at West Cambridge and Eddington, and Wain Estates' evidence identifies it as available now and capable of delivering homes within five years, a stance echoed by the HELAA, 2026. At this scale it can make a meaningful contribution without the lead-in periods and strategic infrastructure requirements of the largest allocations, complementing rather than replacing them.

Conclusion

For these reasons, Wain Estates considers that Policy S/DS is not justified or effective.
The Proposed Submission Plan continues to rely substantially upon large strategic sites whose delivery is dependent upon significant infrastructure and whose contribution is weighted towards the later part of the Plan period. This risk is expressly reflected in the Plan's acknowledgement that sustained delivery at or above the housing requirement is not anticipated until the second half of the Plan period.

At the same time, the strategy affords a comparatively limited role to sustainable existing rural settlements and relies substantially upon unidentified windfall development to supplement the portfolio of specifically identified small and medium-sized sites.

A more balanced Development Strategy should therefore:

• provide a greater role for sustainable Rural Centres and Minor Rural Centres;
• identify a wider portfolio of small and medium-sized, non-strategic housing sites capable of contributing earlier and throughout the Plan period;
• reduce reliance upon unidentified windfall development; and
• provide greater housing choice and certainty of delivery while strategic sites and associated infrastructure are brought forward.

Land at Girton Road, Girton (Site ID 115170) represents such an opportunity. Its allocation for approximately 75 homes would diversify the housing land portfolio, provide planned and comparatively early delivery at a sustainable Minor Rural Centre, include affordable housing, and respond directly to the residual local housing need evidenced by Girton's 88-home neighbourhood requirement.