Greater Cambridge Local Plan: Proposed Submission

Recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may want to amend the ending year to 2047 to maintain the 21-year plan period.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

More planned development, in the form of small-medium sized allocations, should be designated in this plan to ensure delivery of housing in the first five years of the plan.

Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Plan for more home allocations to mitigate burden on neighbouring areas, use of private vehicles and sufficient homes support identified housing need.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Request the policy be removed and content required within an application’s Design and Access Statement and/or Planning Statement, regardless of scheme size.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Request for 20% minimum BNG be removed

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Amend policy to a ‘sliding scale’ for the percentage of such dwellings per site (lower percentage on larger schemes) or the threshold of 20 units increased to in the region of 70 units.
Amend paragrapgh 3a enable unsold self build and custom plots to be sold on the open market.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Land off Back Road, Linton - site should be allocated for residential development.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

The site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Land off Whitecroft Road, Meldreth - site should be allocated for residential development.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.

Land off Station Road, Over - site should be reconsidered for allocation in the Local Plan.

Note: Please refer to the submission attachments for the correctly formatted full submission, which includes footnotes, figures, tables and appendices.

GLADMAN Greater Cambridge Local Plan Regulation 19 Publication Version
September 2026

CONTENTS
1 Introduction 3
1.1 Context 3
2 Legal Compliance 4
2.1 Duty to Cooperate 4
2.2 Sustainability Appraisal 5
3 National Planning Guidance 6
3.1 National Planning Policy Framework 6
4 Draft Local Plan 7
4.1 Plan Period 7
4.2 Housing Figures and Requirement and Growth Strategy 7
4.3 Development Strategy 9
4.4 Development Management Policies 12
5 Omission Sites 14
5.1 Overview 14
5.2 Land off Back Road, Linton 15
5.3 Land off Balsham Road, Linton 17
5.4 Land off Whitecroft Road, Meldreth 19
5.5 Land off Station Road, Over 21
5.6 Land south of Willingham Road, Willingham 23
6 Conclusions 25
6.1 Summary 25
7 Appendices 26
7.1 Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement 26

1 INTRODUCTION
1.1 Context
1.1.1 Gladman Developments Ltd. (Gladman) welcomes the opportunity to comment on the Greater Cambridge Local Plan Regulation 19 consultation and requests to be updated on future consultations and the progress of the Local Plan.
1.1.2 Gladman specialises in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.
1.1.3 Gladman has land interests across Greater Cambridge that are not included within the plan for allocation, further detail about each omission site is provided in Section 5. These sites are:
• Land off Back Road, Linton
• Land off Balsham Road, Linton
• Land off Whitecroft Road, Meldreth
• Land off Station Road, Over
• Land south of Willingham Road, Willingham

2 LEGAL COMPLIANCE
2.1 Duty to Cooperate
2.1.1 The Duty to Co-operate, as a legal test, was rescinded by the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023. However, engaging with prescribed bodies on relevant strategic and cross boundary matters remains an important part of the plan making process. It will be important for Greater Cambridge to demonstrate how it has engaged constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of preparing the Local Plan.
2.1.2 Both the 2024 NPPF and the recently passed 2026 NPPF emphasise the need for local planning authorities to maintain effective cooperation during the plan-making process (in paragraphs 24-28 and in PM10 respectively). They confirm that this is integral to the production of a sound plan, and that a plan must be positively prepared with a justified strategy for managing growth and meeting identified needs for development, including infrastructure. Cooperation can help to inform considerations as to whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.
2.1.3 Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, for example, unmet housing needs.

2.2 Sustainability Appraisal
2.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, local planning authorities must subject proposals in development plan documents to Sustainability Appraisal (SA) and prepare a report on the findings of the appraisal.
2.2.2 The SA must incorporate the legal requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 and associated directive. The Directive sets out the relevant requirements and considers that the preparation and adoption of a Local Plan should be subject to an environmental assessment as defined in Article 2b), this will include the preparation of an 'environmental report' as defined by Article 2c) and involves information required in Article 5 and Annex I.
2.2.3 Crucially, the SA process should clearly justify its policy choices in meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Local Plan's decision-making and scoring should be robust, justified, and transparent.
2.2.4 Greater Cambridge published their SA in July 2026. Three Strategic Spatial Options were considered:
a. Minimum - Standard Method homes-led.
b. Medium - central scenario employment-led.
c. Maximum - higher employment-led.
2.2.5 Subsequent updates in 2021 led to the minimum and maximum growth levels to being considered as unreasonable. Further options were subsequently considered; however, Gladman's stance is that the growth option proceeded with is insufficient for an area of Greater Cambridgeshire's nature. Further details on this can be found in our Housing Figures and Requirement and Growth Strategy Section (4.3) below.

3 NATIONAL PLANNING GUIDANCE
3.1 National Planning Policy Framework
3.1.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these should be applied within which plan-making and decision-taking. The latest iteration was published in August 2026 however as the Greater Cambridge Local Plan is being prepared under the legacy plan making system the 2024 version of the Framework should be used for the preparation of the Greater Cambridge Local Plan. All references to the NPPF through this document therefore refer to the 2024 version.
3.1.2 The National Planning Policy Framework 2024 sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
• Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified - the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
• Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
3.1.3 The NPPF reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.

4 DRAFT LOCAL PLAN
4.1 Plan Period
4.1.1 As this draft local plan is being written in accordance with previous iterations of the NPPF (i.e. prior to the latest version from August 2026), the plan period must be for a minimum of 15 years.
4.1.2 This draft plan covers years 2024-2045. As outlined in our representation to the Regulation-18 consultation, whilst we support the plan covering additional years above and beyond the minimum of 15 years, we reiterate that the start and end dates should be shifted to be consistent with national policy. The standard method is a forward-looking assessment of housing need taking into account both under and oversupply in its methodology and uses a base period that is required to start from the year that the housing need is calculated. Gladman would recommend that the plan period starts in 2026, i.e. the year in which the plan is scheduled to be submitted to the Planning Inspectorate. The council may then want to amend the ending year to 2047 to maintain the 21-year plan period.

4.2 Housing Figures and Requirement and Growth Strategy
4.2.1 It is noted that the minimum number of homes in the draft document has decreased slightly from the figures from the Regulation-18 consultation - from a minimum of 48,195 new homes to a minimum of 48,069. This is to reflect the annual housing need, which has been calculated at 2,289 dwellings (down from 2,295).
4.2.2 In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach
4.2.3 Gladman is concerned over the seemingly low numbers proposed for the authority, in terms of the economic opportunities that are available and thus the subsequent housing numbers that would support this. Gladman have jointly appointed Turley to explore this further and findings are set out below.
4.2.4 The former Chancellor announced plans, in January 2025, to go 'further and faster' to unlock growth along the Oxford-Cambridge corridor to capitalise upon its potential to be Europe's Silicon Valley and add £78 billion to the UK economy by 2035. The current Minister of State for Housing and Planning subsequently described how 'numerous long-standing barriers to further growth' had been historically preventing the corridor from 'realising its true potential', reporting these to be 'particularly acute in Greater Cambridge. He referred to the Cambridge Growth Company (CGC) having been tasked with the development of an 'evidence base to support an infrastructure- first growth plan and a long-term delivery vehicle' befitting the 'nature, scale and complexity of ambitious and high-quality sustainable growth in Cambridge and its environs'. This was found to require 'a delivery vehicle with the necessary powers, authority and access to finance', leading the Government to conclude that 'a centrally led development corporation' (DC) would be the best option for delivering 'nationally significant growth in Greater Cambridge'. An 'ambitious funding package' of up to £400 million would initially be made available to such a body to 'remove barriers to sustainable growth and boost housing supply', with this having notably been 'welcomed' by the leaders of both Councils.
4.2.5 The Councils could have been far more ambitious in developing the draft Plan, targeting the creation of at least 90,900 jobs - to align with the higher growth scenario presented in the Employment and Housing Needs Update (EHNU) – rather than the 73,300 proposed at draft Policy S/JH.
4.2.6 It should consequently plan, as a minimum, for what the EHNU reports to be the associated need for circa 2,829 homes per annum, rather than meeting only the minimum need that is currently suggested by the standard method (2,289dpa). This is clearly permitted by an NPPF that allows housing requirements to be 'higher than the identified housing need if, for example, it. reflects growth ambitions linked to economic development or infrastructure investment'. It is indeed this that was last year cited by the Oxford Growth Commission, at the opposite end of the corridor, in concluding that 'delivery above the new standard method will be required' since that was acknowledged to not 'make any specific allowance for a growth strategy' and doing so would 'support the potential for economic growth in a sustainable way'.
4.2.7 Simply providing for the number of homes calculated under the standard method (2,289 dpa) would lead to there being an insufficient number of homes in Greater Cambridge if this area does indeed create more than 73,300 jobs, the draft Plan notably acknowledging this prospect in discussing the need for 'flexibility in employment land in case the market delivers more jobs than anticipated. This logic can naturally extend to cover the homes in which workers would live, as the alternative would be expected to only increase the burden on neighbouring areas that were already relied upon to fill some 39% of the jobs that existed in the area's workplaces as of 2021. It would likely thus increase use of private vehicles where some 84% of those commuting more than 10km to work in Greater Cambridge travelled by car, compared to only 46% of those travelling shorter distances.
4.2.8 Further details on this matter have been appended to this representation under Appendix 1: Technical Note on Planned Job Growth and the Proposed Housing Requirement.

4.3 Development Strategy
4.3.1 Gladman supports many of the objectives of the draft Local Plan, recognising the need for the planning system to respond to and reach an appropriate balance between the varying significant interests involved in plan preparation.
4.3.2 Further, Gladman supports the objective of delivering a diverse range of housing in a variety of tenures, size and type to meet future needs of Greater Cambridge residents.
4.3.3 However, Gladman object to the spatial development proposed as part of this draft local plan, as set out in draft policy S/DS - Development Strategy. Whilst we concur with the settlement hierarchy, in terms of the settlements within the hierarchy itself as well as their respective designation, we disagree with the allocations proposed for the tiers within the hierarchy.
4.3.4 Across the 14 Minor Rural Centres proposed, only Melbourn has draft residential allocations, totalling 145 units (i.e. one site for 125 units, and one site for 20 units). Whilst we do not object with this proposal for the settlement, we disagree with approach to not allocate any further land for residential development across any of the other 13 settlements in this tier.
4.3.5 It should be noted that the draft local plan proposes employment allocations within a number of Minor Rural Centres and Group Villages, such as policy S/RRA/CRH which allocates 0.40 hectares of land for office development in Hauxton, policy S/RRA/BBP which allocates 2.11 of land for B2 and B8 development in Swavesey and policy S/RRA/NW which allocates 1.7 hectares of land for office development in Over. Whilst the strategy is positively prepared in supporting employment growth and economic development, it is considered that the approach to residential growth is not similarly positively prepared, resulting in an inconsistency whereby additional employment opportunities are promoted within Minor Rural Centres and Group Villages without corresponding provision for housing. Increasing employment provision in these locations is likely to generate additional demand for housing, and it is therefore considered that a more balanced strategy would support both employment and residential development in order to promote sustainable patterns of growth and reduce the need to travel.
4.3.6 Likewise, settlements identified as Group Villages within the draft settlement hierarchy are also appropriate for proportionate residential development. Settlements such as Meldreth and Over are sustainable settlements which have sufficient services available to allow for further growth.
4.3.7 The other 13 settlements are identified as being appropriate for growth, hence their ranking within the settlement hierarchy. Appropriate levels of development must be allowed to take place to ensure that existing settlements do not stagnate and become unsustainable. Linton, for example, has a demographic imbalance characterised by relatively low numbers of young children and younger adults. A balanced age structure is important in maintaining healthy and sustainable communities, supporting social cohesion, intergenerational interaction and the viability of local services. Increasing the supply of homes capable of meeting the needs of younger households would help address this imbalance, contributing to the long-term social sustainability and wellbeing of the area. Such development should be planned for through allocations rather than being reliant on only windfall development.
4.3.8 It is identified in the Meeting Our Needs section in paragraph 2.41 that the requirement of 10% of land that must be identified for small and medium sized sites by national policy has been met, with 4.3% being identified (allocated), meaning that the remaining 5.7% is through windfall development.
4.3.9 The justification for allocating less than half of this type of development site is explained in paragraph 2.42, where it is stated that further allocations would be extremely challenging (in terms of the larger numbers of sites that would need to be identified) and that planning for development in less sustainable locations would compromise the development strategy related to climate change and net zero carbon, with more car use needed in such locations.
4.3.10 Whilst we acknowledge the impacts on the environment, it would be inappropriate to elect not to plan for appropriate growth in settlements that have been identified in the settlement hierarchy as being sustainable. As above, settlements with no planned growth will, over time, become unsustainable settlements for the communities that live in them. The draft local plan heavily relies on larger developments, including new strategic sites, to deliver within the plan period whilst simultaneously overlooking the needs of the smaller settlements which can inherit growth, but are seemingly being denied this based on officer workload and a push for net zero carbon.
4.3.11 This approach will be unsustainable in the longer term for smaller settlements, and appropriate planned growth must be identified in each of these settlements. As outlined above, Gladman are promoting five sites across Linton, Meldreth, Over and Willingham which would all contribute to maintaining each settlement's sustainability through appropriate and organic growth.
4.3.12 Minor development (i.e. development of less than 10 dwellings, or is less than 0.5ha in size) would not suffice for the sustainability of such settlements. Planned growth is vital for the prosperity and longevity of a settlement, and as such appropriate residential allocations must be included in these locations. The five sites Gladman are promoting all exceed 10 dwellings and 0.5ha and are all suitable for the growth of the respective settlements. Given the reliance on the larger and strategic sites in the draft plan, and that such sites only realistically deliver in the latter years of a plan period, it falls on the smaller allocations to ensure delivery is made within the first five years of the plan to maintain the five year supply.
4.3.13 As outlined, such allocations are limited in number, and as such Greater Cambridge runs the risk of falling below a five-year supply of housing. More planned development, in the form of allocations, should be designated in this plan for small- medium sized sites to ensure delivery of housing in the first five years of the plan. Such sites would need to consist of more than 10 units and be larger than 0.5ha to have a realistic impact on the housing provision.
4.3.14 As above, Gladman is promoting such sites in Linton, Meldreth, Over and Willingham which will support this approach.

4.4 Development Management Policies
4.4.1 Draft Policy CC/SD: Sustainable development and the climate emergency
4.4.2 This policy is not necessary and over-onerous. We argue that the content requested in a Sustainability Statement can easily be included as part of a Design and Access Statement and/or Planning Statement. This appears to be acceptable for minor development applications (within paragraph 3 of the draft policy), however there is no explanation for why there is a requirement for this to be a separate document for medium and large schemes.
4.4.3 We therefore request that this draft policy be removed and any such content required can form part of an application's Design and Access Statement and/or Planning Statement, regardless of the size of the scheme. There is no necessity for the information sought to be in a separate, standalone document when it can easily be incorporated within documentation which is already a requirement.

4.4.4 Draft Policy BG/BG: Biodiversity and geodiversity
4.4.5 We agree with paragraph 1 of this draft policy, as it reflects the legislation under the Environment Act (2021).
4.4.6 However, Gladman objects to paragraph 2 where it has a requirement of 20% Biodiversity Net Gain (BNG). Government guidance confirms that there is a requirement of at least 10% BNG on site. This paragraph must therefore be removed to reflect both national guidance and the Environment Act (2021) - Schedule 7A Part 1 para 2(3) and Schedule 2a para 3(2) which confirms that required amount is at least 10%.
4.4.7 It is noted that 20% is only requested where it is 'feasible and effective.' However, given that the request is 10% higher than what is required by national policy, inevitably the majority of the development industry will be seeking exemptions with the primary focus being the viability of a scheme. Such an exercise is unnecessary and overly onerous to result in a requirement that is already set nationally. Therefore, the request for 20% minimum BNG should be removed

4.4.8 Draft Policy H/CB: Self and Custom Build Homes
4.4.9 Gladman agree with the principles of this policy, as those who wish to commission/build their own home can play an important part in an LPA's housing numbers and delivery. Such avenues are becoming more popular and so an appropriate mechanism should be in place via policy to accommodate this type of development.
4.4.10 The draft policy requires all developments of 20 or more dwellings to provide at least 5% self or custom build plots. Whilst Gladman acknowledges the importance of self and custom build units, having a 5% requirement on schemes of just 20 units or more would surmount to a significant number of such units being a policy requirement.
4.4.11 It is suggested that this policy is amended to have a 'sliding scale' for the percentage of such dwellings needed per site (i.e. a lower percentage on much larger scheme, as this will still provide a larger number of self/custom build dwellings). Alternatively, the threshold of 20 units should be increased to a number in the region of 70 units, which is the approach being taken by Tonbridge and Malling in their draft local plan.
4.4.12 We disagree with paragraph 3a in this policy. We concur with the 12-month turnaround to sell such plots as self or custom build dwellings, however should they not be sold as such dwelling-types then they should be sold as open market plots, rather to registered providers as affordable dwellings. There is already a requirement of 40% of units on major developments to be affordable units (under draft policy H/AH: Affordable Housing), which is already a significant number per site. Additionally, it is likely that revised legal agreements will need to be drawn up if the plots switch from open market dwellings (marketed as self/custom builds) to affordable units, causing more unnecessary delays, costs and officer time to a scheme that has already been determined.

5 OMISSION SITES
5.1 Overview
5.1.1 Gladman are promoting a number of sites that have not been proposed for allocation within the Local Plan. For the reasons set out in response to the development strategy and housing delivery, further sites will be required to ensure delivery of the overall housing requirement of the plan. Each of the sites represents a suitable, achievable and sustainable site that could be included within the Local Plan.

5.2 Land off Back Road, Linton
5.2.1 Linton is designated as a Minor Rural Centre in the draft settlement hierarchy (Policy S/SH). With an estimated population of around 4,500, it is a sustainable location for growth.
5.2.2 Gladman is promoting Land off Back Road, Linton (SHLAA ref: Site 197) for a high- quality residential scheme of 75 new homes and associated community infrastructure. The 3.97-hectare site, as shown on Figure 1 below, offers an ideal opportunity for sustainable growth in Linton and would represent an organic extension of the village. The site is currently subject to a planning application (ref 26/01304/OUT) for 75 units.
5.2.3 The site comprises a single agricultural field on the northwestern side of the village. It is well-related to the existing settlement edge of Linton, lying immediately adjacent to the established built-up area. This close relationship to the settlement ensures that the site is visually and functionally connected to the existing community, while maintaining a logical and defensible boundary with the countryside beyond.
5.2.4 The site is sustainably located within easy walking and cycling distances of local facilities and the public transport network. Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops located to the southeast of the site on Back Road that provide links to the local area and further afield within South Cambridgeshire
5.2.5 The site can deliver a wide range of market and affordable homes to meet the district's general and specialist housing needs, with the potential to deliver around 75 high-quality new homes including a policy compliant level of affordable homes. The site would be deliverable in the short term and would help to increase the supply and choice of housing in Linton.
5.2.6 The site is not subject to any statutory ecological, or landscape designations. The site is free of any overriding technical constraints that would frustrate its delivery and is in a sustainable location for growth.
5.2.7 As above, there is an over-reliance on larger sites to come forward and be built out within the plan period. There needs to be a more proportional breakdown to allow for organic growth in suitable settlements (as broken down in the settlement hierarchy, draft Policy S/SH) to ensure that there are appropriate levels of development in these locations. The most appropriate way to resolve these issues would be to approach a greater number of small-medium sized sites, as these not only assist with the overall housing need but also greatly assist with the delivery in the first few years of a local plan, and thus give further reassurance to the 5-year housing land supply.
5.2.8 Land off Back Road, Linton is a suitable, available, and deliverable site that will enable the Council to meet the need for new homes in the immediate five-year period. Gladman can confirm that there is no known physical, environmental, legal or ownership restriction that would impede the successful delivery of the site. On this basis, the site should be allocated for residential development.

FIGURE 1: LAND OFF BACK ROAD, LINTON

5.3 Land off Balsham Road, Linton
5.3.1 Gladman is also promoting Land off Balsham Road, Linton for residential development. The site is also subject to a planning application (ref 26/02429/OUT) for 65 dwellings. The site extends to a total area of 7.70 acres, with the site's location and the extent of the land under promotion by Gladman shown in Figure 2 below.
5.3.2 Located to the east of the settlement, Land off Balsham Road is capable of delivering 65 dwellings and, as outlined in 5.2.4 above, Linton benefits from an excellent range of services and facilities that meet the daily needs of its residents, including a nursery, infant school, junior school, village college, community sports centre, doctors' surgery, pharmacy, dentist and a convenience store. There are bus stops around 300m to the west of the site provide links to the local area and further afield within South Cambridgeshire.
5.3.3 The site comprises of one agricultural field with residential properties running alongside its western and south-western borders. The northern side runs along Balsham Road which would provide the access, with the east border having thick tree coverage, and the southern boundary lying north of further agricultural fields.
5.3.4 A policy-compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.3.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.3.6 In its SA score (site reference 40336), the site's only negative is associated with Objective 8, which relates to Efficient use of land. Gladman disagrees with this conclusion, as making the site available for residential development is wholly appropriate given the location in the settlement, the settlement itself, and the site's very limited number of constraints. Residential development in this location is suitable in the context of the settlement and, given its small-medium size, will greatly assist with the housing supply in the early years of the local plan.
5.3.7 In light of the above, the site off Balsham Road should be reconsidered for a residential allocation as part of this draft local plan.

FIGURE 2: LAND OFF BALSHAM ROAD, LINTON

5.4 Land off Whitecroft Road, Meldreth
5.4.1 Meldreth is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 1,900 people, it is a suitable settlement for small- medium scale residential growth. Gladman are promoting Land off Whitecroft Road for residential development.
5.4.2 Land off Whitecroft Road is capable of delivering around 85 homes and relevant community infrastructure. The entire site is approximately 6.0 acres, and its geographical position makes it a commutable distance to larger settlements, such as Royston to the south and Cambridge to the north. It lies near excellent transport links, with the A10 just one minute drive away to link with the aforementioned settlements, and a railway station just 600 metres away with excellent links to Cambridge and beyond.
5.4.3 The site is comprised of one agricultural field, with further agricultural fields immediately to the north. Whitecroft Road runs along its western boundary, with residential dwellings to the south and east. The site's location can be seen in Figure 3 below.
5.4.4 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need
5.4.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.4.6 Any site-specific issues such as surface water flooding can be alleviated through design and layout of a scheme, as well as any flood-mitigation measures required.
5.4.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links (both road and rail), size and overall location make the site an ideal residential prospect for the draft local plan. Given that more small-medium sites are needed, this site in Meldreth should be reconsidered for residential allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply. Additionally, the site lies within reasonable distance to a railway station in a confirmed top 80 Travel to Work Area, and whilst the train frequency is not throughout every day, clearly the government's push for more development by railway stations is a consideration for this site and thus NPPF (2026) Section S5 paragraph 1h can be partially applied.

FIGURE 3: LAND OFF WHITECROFT ROAD, MELDRETH

5.5 Land off Station Road, Over
5.5.1 Like Meldreth above, Over is designated as a Group Village in the draft settlement hierarchy. With an estimated population of around 3,000 people, it is a suitable settlement for small-medium scale residential growth. Gladman are promoting Land off Station Road for residential development, with an application being submitted in due course.
5.5.2 Land off Station Road is capable of delivering around 70 homes and relevant community infrastructure. The entire site is approximately 8.6 acres, with strong commuter linkages, as it is a short drive to the A14 which then joins Cambridge to the east.
5.5.3 The site is suitably positioned, with it naturally 'rounding off' the settlement at its western side, with it effectively 'in-filling' within Station Road and New Road (i.e. the village is not expanding any further outwards).
5.5.4 The site consists of one field, and is surrounded by residential use to the north, Station Road and New Road to the west and south, and a sports pitch to the east. The site's location can be seen in Figure 4.
5.5.5 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement.
5.5.6 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Over itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Over should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 4: LAND OFF STATION ROAD, OVER

5.6 Land south of Willingham Road, Willingham
5.6.1 Land south of Willingham Road is capable of delivering around 100 homes and relevant community infrastructure. The entire site is approximately 11 acres, and it lies on the main access road into the settlement from the west. The main commuter route for Willingham is a short drive south of the settlement, where vehicles can join the A14. Given the site's position to the western side of Willingham, any vehicular impacts will be minimal due to commuters only driving through a small part of the settlement (along Willingham Road/Over Road and Station Road) before exiting the village towards the A14. The majority of dwellings are situated to the north and east of the settlement, thus meaning that there would be no notable impact upon the existing residents.
5.6.2 The site comprises of one, flat, agricultural field, with further fields immediately to the west and south, Willingham Road adjacent to the border to the north and one residential property to the east. The site's location can be found in Figure 5.
5.6.3 A policy- compliant level of affordable housing could be provided, in a range of sizes and tenures. The site will accommodate a range of house types and sizes informed by local need.
5.6.4 Suitable mitigation and precautionary measures will be implemented on site to ensure that there are no significant adverse effects on ecology and 10% biodiversity net gain can be achieved through new habitat creation and enhancement
5.6.5 The site has no notable constraints for development. Only minor flood risk (surface water) runs along Willingham Road on the site's northern boundary. Such a constraint can easily be mitigated against with careful design and layout, as well as any required mitigation measures.
5.6.6 The 30mph zone can be extended from its current position on Willingham Road (just west of Haden Way) to the western side of this site. This would provide further safety to existing residents as well as any future residents of the site.
5.6.7 The site is suitably positioned within the village and, given its size, will allow for an appropriate level of dwellings to be formed in the context of the wider settlement. Its strong transport links, size and overall location make the site an ideal residential prospect for the draft local plan and for Willingham itself. There are no notable constraints for the site of any kind and, given that more small-medium sites are needed, this site in Willingham should be reconsidered for allocation to ensure that there is no risk to the housing need not being met over the plan period, as well as assisting with the 5-year housing land supply.

FIGURE 5: LAND SOUTH OF WILLINGHAM ROAD, WILLINGHAM

6 CONCLUSIONS
6.1 Summary
6.1.1 Gladman welcomes the opportunity to comment on the Greater Cambridge Local Plan and the spatial approaches that are currently being explored by the Council. These representations have been drafted with reference to the National Planning Policy Framework (NPPF 2024 - unless otherwise specified) and Planning Practice Guidance.
6.1.2 Gladman has provided comments on a number of the objectives and spatial approaches that have been identified in the Council's consultation material and recommend that the matters raised are carefully explored during the process of undertaking the new local plan.
6.1.3 We hope you have found these representations informative and useful towards the preparation of the Greater Cambridge Local Plan.
6.1.4 Gladman welcomes any future engagement with the Council and if you would like to discuss this representations or other matters, please contact us at policy@gladman.co.uk.