Greater Cambridge Local Plan: Proposed Submission

That the Local Plan is modified to allocate Scotland Park as a strategic mixed-use new settlement, comprising approximately 10,000 homes, employment land, supporting infrastructure, community facilities and extensive public open space, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of PX Land Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 These representations build on those submitted by our client in response to the Regulation 18 Local Plan Consultation. As set out in those earlier representations, our client is the sole landowner of Scotland Farm, Scotland Road, Dry Drayton, Cambridgeshire ('the Site'). The Site forms part of the wider Scotland Park proposal and is referred to on that basis throughout these representations. A location plan of the Site is shown at Appendix 1.

1.1.3 Alongside the response to the Regulation 18 Consultation, the Site has been promoted by PX Land Ltd during the Calls for Sites process. Scotland Park was promoted as a new sustainable settlement comprising:
• 10,000 new homes (market and affordable housing).
• 160 hectares (ha) of public open space.
• 10ha for a town centre hub.
• Scotland Farm Sustainable Transport Hub to support the Cambourne to Cambridge Busway.
• 26ha for a business hub; and
• 20ha for education purposes (comprising one secondary school and up to four primary schools).

1.1.4 Since the publication of the Regulation 18 representations in January 2026, the Cambourne to Cambridge Busway was approved in September 2026¹. This includes the provision of the Scotland Farm Sustainable Transport Hub, which is within the boundary of the Scotland Park new settlement.

1.1.5 These representations follow on and supplement the representations submitted as part of the Regulation 18 Consultation. For completeness, the submitted representations are provided at Appendix 2. Details on the Site physical and planning context and PX Land is set out in the Regulation 18 representations; these have not been repeated as part of these representations for brevity.

1.1.6 However, our client is currently in discussion with a number of delivery partners for both housing and commercial sectors. They are also in contract with a motorway service station provider. Our client in conjunction with these partners is investigating suitability of the delivery of early parcel within the new settlement. They have also had interests from renewable energy providers due the ability of these providers to be able to easily plug into the existing infrastructure.

1.2 Regulation 19 Consultation

1.2.1 The Regulation 19 consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 For the Plan to be 'sound', it must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a revised NPPF was published in August 2026, it is understood that the Greater Cambridge Shared Planning Service intends to submit the emerging Local Plan to the Inspectorate in December 2026. Accordingly, and having regard to Appendix A of the 2026 NPPF, our client accepts that the Plan will be assessed against the 2024 NPPF.

1.2.3 Paragraph 36 states that a Local Plan must be:

a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.

c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.

d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

1.2.4 Our client does not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.2.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of its publication. In this context, our client strongly contends that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to the proposed development in the context of the Regulation 19 Pre-Submission Local Plan.

2.1.2 Our client has examined the housing delivery forecast that has been calculated as part of the AECOM 2026 Addendum² against the previous forecast provided as part of the Regulation 18 consultation in January 2026³ and has concerns about the Plan being able to ensure constant delivery throughout the Plan Period.

2.1.3 Our client has also analysed the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our client does not consider that Greater Cambridge has allocated a sufficient amount of commercial land to support Greater Cambridge's ambitions for growth, particularly with regard to Mid Tech accommodation.

2.2 Overreliance on New Settlements that lack Strategic Infrastructure

2.2.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations with 28% of housing delivery on the edge of Cambridge, 43% at new settlements and with rural areas accounting for approximately 14% (paragraph 3.2.93). It adds that the majority of development is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.2.2 The Addendum further states that new allocations will be phased from 2033/34 onwards following completion of the Grafham Water Supply Transfer and the delivery of other supporting infrastructure. Whilst our client acknowledges the position, it has concerns regarding the extent to which both allocations can be relied upon given their dependence on the timely delivery of key pieces of infrastructure. These allocations are considered in further detail below.

Grange Farm New Settlement

2.2.3 The Addendum states that the Grange Farm new settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure to unlock the Site for development is the delivery of the Cambridge South East Transport (CSET) Phase 2 Scheme.

2.2.4 CSET would provide a new busway between a new A11 travel hub and Cambridge

Biomedical Campus.

2.2.5 The delivery of CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of CSET are yet to be determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Therefore, our client considers that first completions in 2034/35 is unrealistic, as significant infrastructure is required to be in place prior to delivery of new homes. Any delay in the delivery of CSET, or other associated sustainable transport infrastructure projects, will inevitably delay the delivery of housing completely or limit the number of new homes in the initial phase.

2.2.6 In contrast, Scotland Park includes the sustainable travel hub, which has been located to support the Cambourne to Cambridge Busway (C2C), which is in PX Farms ownership. Scotland Park was chosen as the appropriate location for a Travel Hub given its easy access to the A428 and its low environmental sensitivity, despite it being located in the Cambridge Green Belt.

2.2.7 The Travel Hub has been designed to accommodate 2,000 car parking spaces, 300 cycle parking spaces and other facilities, such as a building and specialised LED lighting. Once completed, it is anticipated that there will be buses every 10 minutes from Cambourne to Cambridge.

2.2.8 C2C has been granted a Transport and Works Act Order (TWAO). It is anticipated that construction will be completed between January 2027 and December 2030. As the Order has already been approved, fully funded by the Greater Cambridge Partnership, it is considered that the delivery of a new settlement at PX Farms is a preferable location than the proposed new settlement at Grange Farm.

2.2.9 Paragraph 77 of the NPPF (2024) states:
"The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements. provided that they are well located and designed and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes"

2.2.10 Our client also notes that the delivery of Bourn Airfield is limited to 500 dwellings until C2C is delivered. Although the circumstances at Grange Farm are not identical, this further illustrates dependencies in the Council's spatial strategy on strategic transport that have not been approved, which consequential implications for the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET, therefore, represents a material risk to the assume delivery of 2,550 dwellings at Grange Farm during the Plan Period.

2.2.11 As C2C has already been granted consent through the TWAO, Scotland Park is considered to meet the criteria set out in 2024 NPPF Paragraph 77, unlike Grange Farm. The TWAO also includes new and enhanced public rights of way, leading into Cambridge, thereby providing a genuine choice of transport modes for future residents, in line with the NPPF.

2.2.12 Scotland Park therefore represents a credible and sustainable location for future growth which benefits from a higher degree of certainty regarding the delivery of key strategic transport infrastructure. Given that C2C is expected to be operational in advance of first occupations, the Site has the potential to support housing delivery earlier in the Plan period and with less reliance on the future delivery of major infrastructure projects. In this regard, Scotland Park represents an opportunity to strengthen the resilience and flexibility of the emerging Local Plan's development strategy and should be allocated for mixed-use development in future iterations of the Local Plan.

Cambourne North

2.2.13 Cambourne North is reliant on the delivery of two key pieces of transport-related infrastructure, namely C2C and East West Rail. As stated above, our client acknowledges that C2C has been approved. However, it is understood that the Highways Authority does not consider the delivery of East West Rail to be an automatic prerequisite to the commencement of housing development at Cambourne North, and as a minimum would require certainty on the timeframe for opening of the station. Our client therefore questions whether the allocation of Cambourne North is appropriate, especially given that C2C is also required to support the allocation in the current Local Plan of West Cambourne (2,350 additional homes granted in 2017 under Council reference: S/6438/07/O).

2.2.14 As highlighted in our client's Regulation 18 representations, there are no guarantees that a future government would be as committed to East West Rail as the current incumbent. Therefore, and to ensure resilience in its spatial strategy and housing delivery, the emerging Local Plan should identify growth at locations which benefit from committed strategic transport projects, including at Scotland Park.

2.2.15 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to significant infrastructure and timing risks. Whilst our client does not suggest that these locations will not come forward, the degree of reliance placed upon them introduces a level of delivery risk within the housing trajectory. In this context, Scotland Park should be considered as an additional allocation within the emerging Local Plan. Benefitting from the approved C2C scheme and associated Sustainable Transport Hub, the Site has the potential to provide a more immediate and infrastructure-led growth opportunity, thereby strengthening the resilience, flexibility and effectiveness of the Local Plan's overall development strategy. It is also adjacent to existing infrastructure, off the A428 Junction and has other infrastructure capabilities that can be utilised immediately, such as power. Therefore, Scotland Farm is considered to be more deliverable than the other proposed new settlements as it can be delivered without relying on the delivery of significant infrastructure. The Site's location also means that it can take advantage of the Government's emphasis on the Oxford to Cambridge Corridor.

2.3 Concerns over the delivery of proposed allocations contributing to the Local Plan Headroom

2.3.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). The Addendum continues to state that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding the new settlements that have been allocated (paragraph 3.2.76).

2.3.2 The headroom figure is reliant on the delivery of the new settlements, which are delivered later in the Plan Period, once the infrastructure is provided, such as CSET. Therefore, it is considered that additional housing should be provided to ensure resilience and that the headroom is maintained.

2.3.3 The 2026 Addendum further states that by the end of the Plan period, Grange Farm and Cambourne North are proposed to deliver up to 300 dwellings per annum and Cambridge East, up to 350 dwellings per annum.

2.3.4 Our client's Regulation 18 representations noted that the average housing delivery on sites of 5,000 dwellings or larger was substantially below 300 dwellings per annum, as set out in the latest Lichfields Start to Finish Report (2024)⁴. Therefore, our client maintains that an assumed delivery figure of 200 dwellings per annum would be much more realistic. Although, this level of delivery would only be once the required infrastructure is established.

2.3.5 Therefore, if 200 dwellings per annum were to be delivered at the three new settlements, as opposed to 300 dwellings per annum assumed in the 2026 Addendum, then it would result in a shortfall of 2,850 dwellings - this is significant. In addition, Greater Cambridge already acknowledge that there is a shortfall of housing delivery at the end of Plan Period (p63 of the 2026 Addendum) against the standard methodology figure. The Addendum notes that this shortfall will likely be offset against over delivery in previous years, but as stated in these representations, there is a significant concern that the over delivery will simply not materialise.

2.3.6 Accordingly, Scotland Park has the potential to form part of a more robust and resilient spatial strategy, helping to address any shortfall that may arise. As noted above, Scotland Park is anticipated to be capable of delivering approximately 200 dwellings per annum once the C2C infrastructure is established, thereby making a meaningful contribution to housing supply during the Plan period. Alongside the C2C it has existing infrastructure, meaning that housing can be delivered more quickly.

2.3.7 The provision of another additional new settlement, which benefits from the sustainable transport hub due to C2C, will ensure that the Local Plan can deliver the amount of housing required to ensure a consistent supply during the entire Plan Period thereby making the Plan 'sound' as per the NPPF definition. Accordingly, Scotland Park should be identified as an additional allocation in the Local Plan.

2.4 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs

2.4.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.4.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Space Needs (prepared by Iceni in March 2025)⁵. The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace and that these locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide the "optimum locations" (paragraph 7.21).

2.4.3 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.4.4 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.4.5 Notwithstanding the above, Scotland Park is ideally located to support commercial, warehouse and logistic uses, as illustrated in the Vision Document which allows for a 26ha for Business Hub. There is already an existing B8 use on the Site, which can act as a catalyst to bring in more commercial uses. These commercial uses can help to open up the Site more sustainably.

2.4.6 Scotland Park is adjacent to the Strategic Road Network, benefits from on access directly to the A428, has an appropriate access road within the Site and, therefore, is considered to be an optimum location as set out in the Report. It is noted that the accessibility of the Site is likely to be further enhanced with the current upgrades to the A428 at Black Cat to Caxton Gibbet (due to be open in 2027)6, contributing towards the government's increasing emphasis on the Oxford to Cambridge Corridor. The delivery of an early phase of employment generating uses is considered appropriate and would act as a catalyst for the wider site to come forward.

2.4.7 The proposed allocations for industrial growth are focused on the accessibility to the A14, yet Greater Cambridge's own evidence points to the A428 as being an appropriate location, particularly as it is within the Oxford to Cambridge Corridor. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the A14. However, our client considers that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to the A428 provides a suitable alternative, particularly with the completion of the Black Cat to Caxton Gibbet improvements.

2.4.8 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and future residents of Scotland Park.

2.4.9 Therefore, the Site should be considered favourably for employment uses, as part of the overall Scotland Park development.

2.4.10 The Needs Assessment also states that there is a clear need for Mid Tech. Mid Tech comprises a mix of Class 'B' uses with larger office space. These types of uses support Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan period.

2.4.11 The Emerging Local Plan states that Mid Tech is an "emerging need" (paragraph 2.69). Mid Tech growth will be provided at Eddington and Cambridge East, with Cambourne delivering in the longer term (paragraph 2.69). However, these allocations do not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.4.12 Paragraph 7.22 of the 2025 Needs Assessment states:
"An additional edge of centre location with closer city proximity and links would be preferable, or ensuring enhanced connectivity to current and future proposals"
2.4.13 The Needs Assessment adds that the new phase at Eddington meets this requirement for Mid Tech. However, the recent approval granted at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Classe E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁷. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.4.14 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report, and it is crucial that alternative provision is made to support these Mid Tech uses. Scotland Park fully complies with Paragraph 7.22 of the 2025 Needs Assessment. It is considered to be an edge of centre location. The Illustrative Masterplan in the Vision Document, locates the Business Hub adjacent to the existing junction (Toft/Hardwick/Dry Drayton) access/egress. Therefore, it is considered to be suitable to support commercial uses, particularly Mid Tech.

2.4.15 Emerging Policy S/CE (Cambridge East) states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, including 20,000sqm (GIA) of B2/B8 space for both Mid Tech and general industrial uses.

2.4.16 As housing is set to be delivered from 2032, it is considered that the earliest employment space could be delivered is also from 2032. It is clear that there is a shortfall in Mid Tech employment space in the early years of the Local Plan. This is acknowledged in the 2025 Report (paragraph 7.22), which states:

"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period, which would not meet shorter term demand"

2.4.17 Therefore, there is a contradiction between the Greater Cambridge Local Plan and the evidence behind it with regard to the immediate need for Mid Tech.

2.4.18 Paragraph 7.22 of the 2025 Report further states that Mid Tech development should

ensure enhanced connectivity. Thanks to the provision of the Scotland Farm Sustainable Transport Hub and the proximity of the new settlement to Cambridge, it is considered that the Site adheres to these criteria.

2.4.19 In conclusion, the evidence behind the emerging Local Plan sets out a need for additional employment space to support Mid Tech uses and warehousing and distribution facilities in alternative locations. The 2025 Report provides criteria on the ideal location for a new Mid Tech location. The Site is ideally located to support Greater Cambridge's ambitions to support its knowledge intensive sectors, and it should therefore be allocated for residential-led mixed-use development in future iterations of the Local Plan.

2.5 Emerging Policy S/GB - The Green Belt

2.5.1 There have been no changes to the text surrounding emerging Policy S/GB since the Regulation 18 version of the Local Plan.

2.5.2 As stated in our client's representations to the Regulation 18 Local Plan, the land to the east of Scotland Farm, although within the new settlement, is located within the Green Belt. The land within the Green Belt equates to approximately 30% of the overall Site. It should therefore be noted that the majority of the Site is not within the Green Belt, although it is acknowledged that the land to the east of Scotland Road is required to support the delivery of both the Scotland Farm Transport Hub and additional development as part of the new settlement.

2.5.3 The new travel hub for C2C is located in Parcel HA2 and the remainder in a huge Outern Area Parcel (OA11), comprising 1,375.13ha.

2.5.4 As the sustainable travel hub is located in Parcel HA2, our client considers that the Site is suitable to support a sustainable new settlement as it benefits from proximity to the sustainable Travel Hub. The Vision Document that accompanied the Regulation 18 representations, set out suitable landscape mitigation to reduce the impact on the wider landscape.

2.5.5 As part of its Regulation 18 representations, our client provided justification that the Site falls within the definition of Grey Belt as set out in national policy, and should, therefore be designated as part of the emerging Local Plan.

2.5.6 The previous 2021 Green Belt Assessment⁸ concluded that the Parcels above 'strongly' contributed to purposes to the Green Belt (as set out in Paragraph 148 of the 2024 NPPF), with a focus on the merging of settlements.

2.5.7 In 2026, the Council published an updated Green Belt Assessment. The aim of this assessment was to identify sites that could be considered as Grey Belt.

2.5.8 The assessment notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 3.14).

2.5.9 The findings of the July 2026 Green Belt Assessment in relation to Parcels HA2 and OA11 are set out in the table below:

Table 2.1: Conclusions on Parcels HA2, and OA11 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

2.5.10 Our client however considers that the assessment of land's contribution to the purposes of the Green Belt should be considered on its own merits, rather than assessing significantly sized parcels. Parcel HA2 has already been considered suitable for release as it will accommodate the new sustainable transport hub and therefore, the conclusions set out in the updated 2026 Assessment are considered out of date.

2.5.11 The assessment of Parcel OA11 is therefore inappropriate and the findings are inaccurate. The Vision Document (Appendix 2 of the Regulation 18 representations) provides mitigation that reduces that impact.

2.5.12 Therefore, it is considered that the Site is considered suitable for development as 'Grey Belt' and should be allocated in the emerging Local Plan as it is in accordance with Paragraph 148 of the 2024 NPPF.

2.5.13 As our client considers that the Site falls within the definition of Grey Belt, it has been considered against the criteria set out in Paragraph 155 of the NPPF, which have been carried forward in Policies GB7 and GB8 of the 2026 NPPF, detailed below. It is noted that the criteria below are only relevant to the determination of planning applications. However, it demonstrates the suitability of the Site as a proposed new settlement in the emerging Local Plan.
a) The development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan

2.5.14 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan. The size of the Green Belt land extends to approximately 120ha and represents 0.5% of the Green Belt when compared with the overall Green Belt (26,090ha) of Cambridge¹⁰. If the size of the proposed sustainable Travel Hub were to be removed, given that it has already been approved in the TWAO, then the amount of land to be removed to support the sustainable new settlement represents only 0.4% of the Green Belt.

2.5.15 In addition, as stated in the Vision Document, the development of the Site would provide 160ha of public open space, with a large amount within the Green Belt itself. This includes the provision of greenway corridors to the east of the Site. The landscaping mitigates the impact of the development, thereby not undermining the purposes of the remaining Green Belt and contributing positively the overall landscape in accordance with Paragraph 159 of the 2024 NPPF.

2.5.16 As the Site represents just 0.5% of the Green Belt in Greater Cambridge, and only 0.4% if the Sustainable Travel Hub is removed, and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.

b) There is a demonstrable unmet need for the type of development proposed 2.5.17 As stated above, our client considers that the is a demonstrable need for additional, sustainable new settlements with locational benefits adjacent to approved strategic transport infrastructure.

2.5.18 Therefore, it is considered that these representations have demonstrated that there is a demonstrable unmet need for additional housing to support the Local Plan.
c) The development would be in a sustainable location, with particular reference to paragraphs 110 and 115 of this Framework

2.5.19 As previously stated, the Site incorporates the Scotland Farm Sustainable Transport Hub. The Vision Document also shows how Scotland Park has been designed to be a walkable settlement, comprising linked villages focused on the central Town Centre Hub. The Town Centre hub includes community facilities, such as schools, retail, leisure and health uses.

2.5.20 Therefore, the Site is in accordance with Paragraph 119 of the 2024 NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel and can be accessed by sustainable transport modes.

d) Where applicable, the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

2.5.21 The Site's response to the 'Golden Rules' is set out below:
a) Affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework or (ii) until such policies are in place, the policy set out in paragraph 157 below.

2.5.22 Paragraph 157 seeks a 50% affordable housing provision prior to the adoption of the new Local Plan. As the Site seeks to be an allocation in the emerging Local Plan, it should be considered against part (i).

2.5.23 Emerging Policy H/AH: Affordable Housing states that major sites should be seeking 40% affordable housing. Table 6 of the emerging Local Plan provides the affordable housing tenures for 15 or more dwellings.

2.5.24 Our client is committed to the provision of affordable housing as part of the overall housing delivery on the Site.
b) Necessary improvements to local or national infrastructure

2.5.25 Scotland Park already benefits from high-quality existing infrastructure or infrastructure that has been committed (e.g. its adjacency to the A428 junction, the availability of power supply and drainage, and the future provision of the Scotland Farm Sustainable Transport Hub).

2.5.26 Despite the above, the Vision Document states that the new settlement will provide land for new local infrastructure. Our client would be willing to discuss the requirements in greater detail with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.5.27 It is clear that the development will generate a need for contributions as well as the provision of the land in respect of (inter alia) healthcare, education, employment and skills and transport. Our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations but, as stated, above, is willing to provide the land to support these necessary facilities, such as the schools.

2.5.28 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).

c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.5.29 The Vision Document highlights the importance as providing open space not just to support new residents but residents in nearby settlements.

2.5.30 The Vision Document states that the new settlement is a landscape-led development, creating up to 160 hectares of newly publicly accessible green spaces. The Vision Document also sets out a network of greenway corridors, providing attractive and safe pedestrian routes through the development. The Vision Document further notes that other public open spaces includes sport pitches, community allotments and a community orchard. Therefore, it is clear that the proposed new settlement accords with part c) of the NPPF paragraph 156.

2.5.31 In conclusion, our client considers that significant parts of the Site meet the definition of Grey Belt as set out in national policy and that the Council's strategic parcel-based assessment does not adequately reflect either the approved Scotland Farm Sustainable Transport Hub or the Site's wider role in supporting sustainable growth. The Site benefits from a unique combination of committed strategic transport infrastructure, the ability to deliver a substantial amount of housing, extensive green infrastructure and supporting community facilities. As such, Scotland Park represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge. Its allocation would not only make a significant contribution towards meeting housing needs, but would also improve the resilience, flexibility and effectiveness of the emerging Local Plan by providing an additional growth location capable of delivering homes alongside infrastructure at an early stage in the Plan period. Accordingly, Scotland Park should be identified as a proposed allocation within the emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF. In particular, the Plan has failed to adequately consider Scotland Park as a reasonable alternative growth option and places significant reliance on ambitious delivery assumptions associated with a small number of strategic allocations.

3.1.2 The Plan relies on new settlements, which are dependent on large pieces of infrastructure being delivered, such as CSET, which have not yet been approved. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. Therefore, the housing trajectory is subject to material delivery risk. In contrast, Scotland Park benefits from the approved C2C scheme and associated Scotland Farm Sustainable Transport Hub, providing a significantly greater degree of certainty regarding the delivery of strategic transport infrastructure and supporting a more resilient approach to housing delivery. Scotland Farm benefits from high quality existing infrastructure, such as its proximity to the A428 junction and power, meaning it can be delivered more quickly.

3.1.3 Our client also has concerns over the deliverability of the new settlements to provide more than 200 dwellings per annum, which is considered a more realistic delivery assumption than set out in the latest Lichfield's start to finish report. Consequently, there is a realistic prospect that housing delivery could fall below the levels assumed within the Council's trajectory.

3.1.4 Therefore, the emerging Local Plan should identify additional sustainable growth opportunities capable of strengthening the resilience and flexibility of the development strategy and providing greater confidence that housing needs can be met throughout the Plan period.

3.1.5 The evidence behind the emerging Local Plan notes that there is a need for additional Mid Tech space, and the focus for logistics is on the A14 corridor. Whilst Eddington will make an important contribution, it remains unclear whether the proposed employment allocations will fully address the identified requirement for Mid Tech floorspace. The Site is ideally located as it is adjacent to the Strategic Road Network and can take advantage of the Scotland Farm Sustainable Transport Hub. Its location means that it can take advantage of the government's emphasis on the Oxford to Cambridge Corridor.

3.1.6 Scotland Park therefore represents a logical location to accommodate additional employment growth, including warehousing and logistics, alongside the delivery of housing and supporting infrastructure. There is already an existing B8 use onsite, which can act as a catalyst for more commercial growth, which can open up the Site more sustainably.

3.1.7 Our client maintains that the updated Green Belt evidence base does not adequately reflect the site-specific circumstances at Scotland Park, as it considers large Green Belt parcels, rather than assessing the Site on its own merits. In particular, insufficient regard has been had to the approved Scotland Farm Sustainable Transport Hub and the changed planning context arising from the approved C2C scheme. The Site clearly falls within the definition of Grey Belt.

3.1.8 The proposed new settlement, Scotland Park, provides a suitable additional allocation. As it is a new settlement, it will incorporate a range of services and facilities, within walking distance, including primary and secondary schools as well as the Scotland Farm Sustainable Transport Hub. The Site benefits from a unique combination of committed transport infrastructure, substantial housing capacity, employment opportunities, community infrastructure and extensive public open space. As such, it represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge and would materially strengthen the justification, effectiveness and overall resilience of the emerging Local Plan.

3.1.9 Accordingly, our client requests that the Local Plan is modified to allocate Scotland Park as a strategic mixed-use new settlement, comprising approximately 10,000 homes, employment land, supporting infrastructure, community facilities and extensive public open space, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map. Such an allocation would provide additional flexibility within the development strategy and improve confidence that Greater Cambridge's housing and employment needs can be met throughout the Plan period.

3.1.10 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.


Footnotes:
1 cambourne-to-cambridge-decision-letter.pdf
2 Housing Delivery Study Addendum 2026-06-30
3 Cambridge Housing Delivery Study Addendum October 2025
4 start-to-finish-3 how-quickly-do-large-scale-housing-sites-deliver.pdf
5 EBGCLPIWSSMar25v1Mar25 0.pdf
6 A428 Black Cat to Caxton Gibbet improvements - National Highways
7 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf
8 Greater Cambridge Green Belt Assessment
9 Greater Cambridge Green Belt Assessment
10 https://www.gov.uk/government/statistics/localauthority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

[Please refer to the submission attachments for the appendices.]

Scotland Park should be identified as a proposed allocation within the emerging Local Plan.

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

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of PX Land Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 These representations build on those submitted by our client in response to the Regulation 18 Local Plan Consultation. As set out in those earlier representations, our client is the sole landowner of Scotland Farm, Scotland Road, Dry Drayton, Cambridgeshire ('the Site'). The Site forms part of the wider Scotland Park proposal and is referred to on that basis throughout these representations. A location plan of the Site is shown at Appendix 1.

1.1.3 Alongside the response to the Regulation 18 Consultation, the Site has been promoted by PX Land Ltd during the Calls for Sites process. Scotland Park was promoted as a new sustainable settlement comprising:
• 10,000 new homes (market and affordable housing).
• 160 hectares (ha) of public open space.
• 10ha for a town centre hub.
• Scotland Farm Sustainable Transport Hub to support the Cambourne to Cambridge Busway.
• 26ha for a business hub; and
• 20ha for education purposes (comprising one secondary school and up to four primary schools).

1.1.4 Since the publication of the Regulation 18 representations in January 2026, the Cambourne to Cambridge Busway was approved in September 2026¹. This includes the provision of the Scotland Farm Sustainable Transport Hub, which is within the boundary of the Scotland Park new settlement.

1.1.5 These representations follow on and supplement the representations submitted as part of the Regulation 18 Consultation. For completeness, the submitted representations are provided at Appendix 2. Details on the Site physical and planning context and PX Land is set out in the Regulation 18 representations; these have not been repeated as part of these representations for brevity.

1.1.6 However, our client is currently in discussion with a number of delivery partners for both housing and commercial sectors. They are also in contract with a motorway service station provider. Our client in conjunction with these partners is investigating suitability of the delivery of early parcel within the new settlement. They have also had interests from renewable energy providers due the ability of these providers to be able to easily plug into the existing infrastructure.

1.2 Regulation 19 Consultation

1.2.1 The Regulation 19 consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 For the Plan to be 'sound', it must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a revised NPPF was published in August 2026, it is understood that the Greater Cambridge Shared Planning Service intends to submit the emerging Local Plan to the Inspectorate in December 2026. Accordingly, and having regard to Appendix A of the 2026 NPPF, our client accepts that the Plan will be assessed against the 2024 NPPF.

1.2.3 Paragraph 36 states that a Local Plan must be:

a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.

c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.

d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

1.2.4 Our client does not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.2.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of its publication. In this context, our client strongly contends that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to the proposed development in the context of the Regulation 19 Pre-Submission Local Plan.

2.1.2 Our client has examined the housing delivery forecast that has been calculated as part of the AECOM 2026 Addendum² against the previous forecast provided as part of the Regulation 18 consultation in January 2026³ and has concerns about the Plan being able to ensure constant delivery throughout the Plan Period.

2.1.3 Our client has also analysed the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our client does not consider that Greater Cambridge has allocated a sufficient amount of commercial land to support Greater Cambridge's ambitions for growth, particularly with regard to Mid Tech accommodation.

2.2 Overreliance on New Settlements that lack Strategic Infrastructure

2.2.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations with 28% of housing delivery on the edge of Cambridge, 43% at new settlements and with rural areas accounting for approximately 14% (paragraph 3.2.93). It adds that the majority of development is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.2.2 The Addendum further states that new allocations will be phased from 2033/34 onwards following completion of the Grafham Water Supply Transfer and the delivery of other supporting infrastructure. Whilst our client acknowledges the position, it has concerns regarding the extent to which both allocations can be relied upon given their dependence on the timely delivery of key pieces of infrastructure. These allocations are considered in further detail below.

Grange Farm New Settlement

2.2.3 The Addendum states that the Grange Farm new settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure to unlock the Site for development is the delivery of the Cambridge South East Transport (CSET) Phase 2 Scheme.

2.2.4 CSET would provide a new busway between a new A11 travel hub and Cambridge

Biomedical Campus.

2.2.5 The delivery of CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of CSET are yet to be determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Therefore, our client considers that first completions in 2034/35 is unrealistic, as significant infrastructure is required to be in place prior to delivery of new homes. Any delay in the delivery of CSET, or other associated sustainable transport infrastructure projects, will inevitably delay the delivery of housing completely or limit the number of new homes in the initial phase.

2.2.6 In contrast, Scotland Park includes the sustainable travel hub, which has been located to support the Cambourne to Cambridge Busway (C2C), which is in PX Farms ownership. Scotland Park was chosen as the appropriate location for a Travel Hub given its easy access to the A428 and its low environmental sensitivity, despite it being located in the Cambridge Green Belt.

2.2.7 The Travel Hub has been designed to accommodate 2,000 car parking spaces, 300 cycle parking spaces and other facilities, such as a building and specialised LED lighting. Once completed, it is anticipated that there will be buses every 10 minutes from Cambourne to Cambridge.

2.2.8 C2C has been granted a Transport and Works Act Order (TWAO). It is anticipated that construction will be completed between January 2027 and December 2030. As the Order has already been approved, fully funded by the Greater Cambridge Partnership, it is considered that the delivery of a new settlement at PX Farms is a preferable location than the proposed new settlement at Grange Farm.

2.2.9 Paragraph 77 of the NPPF (2024) states:
"The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements. provided that they are well located and designed and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes"

2.2.10 Our client also notes that the delivery of Bourn Airfield is limited to 500 dwellings until C2C is delivered. Although the circumstances at Grange Farm are not identical, this further illustrates dependencies in the Council's spatial strategy on strategic transport that have not been approved, which consequential implications for the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET, therefore, represents a material risk to the assume delivery of 2,550 dwellings at Grange Farm during the Plan Period.

2.2.11 As C2C has already been granted consent through the TWAO, Scotland Park is considered to meet the criteria set out in 2024 NPPF Paragraph 77, unlike Grange Farm. The TWAO also includes new and enhanced public rights of way, leading into Cambridge, thereby providing a genuine choice of transport modes for future residents, in line with the NPPF.

2.2.12 Scotland Park therefore represents a credible and sustainable location for future growth which benefits from a higher degree of certainty regarding the delivery of key strategic transport infrastructure. Given that C2C is expected to be operational in advance of first occupations, the Site has the potential to support housing delivery earlier in the Plan period and with less reliance on the future delivery of major infrastructure projects. In this regard, Scotland Park represents an opportunity to strengthen the resilience and flexibility of the emerging Local Plan's development strategy and should be allocated for mixed-use development in future iterations of the Local Plan.

Cambourne North

2.2.13 Cambourne North is reliant on the delivery of two key pieces of transport-related infrastructure, namely C2C and East West Rail. As stated above, our client acknowledges that C2C has been approved. However, it is understood that the Highways Authority does not consider the delivery of East West Rail to be an automatic prerequisite to the commencement of housing development at Cambourne North, and as a minimum would require certainty on the timeframe for opening of the station. Our client therefore questions whether the allocation of Cambourne North is appropriate, especially given that C2C is also required to support the allocation in the current Local Plan of West Cambourne (2,350 additional homes granted in 2017 under Council reference: S/6438/07/O).

2.2.14 As highlighted in our client's Regulation 18 representations, there are no guarantees that a future government would be as committed to East West Rail as the current incumbent. Therefore, and to ensure resilience in its spatial strategy and housing delivery, the emerging Local Plan should identify growth at locations which benefit from committed strategic transport projects, including at Scotland Park.

2.2.15 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to significant infrastructure and timing risks. Whilst our client does not suggest that these locations will not come forward, the degree of reliance placed upon them introduces a level of delivery risk within the housing trajectory. In this context, Scotland Park should be considered as an additional allocation within the emerging Local Plan. Benefitting from the approved C2C scheme and associated Sustainable Transport Hub, the Site has the potential to provide a more immediate and infrastructure-led growth opportunity, thereby strengthening the resilience, flexibility and effectiveness of the Local Plan's overall development strategy. It is also adjacent to existing infrastructure, off the A428 Junction and has other infrastructure capabilities that can be utilised immediately, such as power. Therefore, Scotland Farm is considered to be more deliverable than the other proposed new settlements as it can be delivered without relying on the delivery of significant infrastructure. The Site's location also means that it can take advantage of the Government's emphasis on the Oxford to Cambridge Corridor.

2.3 Concerns over the delivery of proposed allocations contributing to the Local Plan Headroom

2.3.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). The Addendum continues to state that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding the new settlements that have been allocated (paragraph 3.2.76).

2.3.2 The headroom figure is reliant on the delivery of the new settlements, which are delivered later in the Plan Period, once the infrastructure is provided, such as CSET. Therefore, it is considered that additional housing should be provided to ensure resilience and that the headroom is maintained.

2.3.3 The 2026 Addendum further states that by the end of the Plan period, Grange Farm and Cambourne North are proposed to deliver up to 300 dwellings per annum and Cambridge East, up to 350 dwellings per annum.

2.3.4 Our client's Regulation 18 representations noted that the average housing delivery on sites of 5,000 dwellings or larger was substantially below 300 dwellings per annum, as set out in the latest Lichfields Start to Finish Report (2024)⁴. Therefore, our client maintains that an assumed delivery figure of 200 dwellings per annum would be much more realistic. Although, this level of delivery would only be once the required infrastructure is established.

2.3.5 Therefore, if 200 dwellings per annum were to be delivered at the three new settlements, as opposed to 300 dwellings per annum assumed in the 2026 Addendum, then it would result in a shortfall of 2,850 dwellings - this is significant. In addition, Greater Cambridge already acknowledge that there is a shortfall of housing delivery at the end of Plan Period (p63 of the 2026 Addendum) against the standard methodology figure. The Addendum notes that this shortfall will likely be offset against over delivery in previous years, but as stated in these representations, there is a significant concern that the over delivery will simply not materialise.

2.3.6 Accordingly, Scotland Park has the potential to form part of a more robust and resilient spatial strategy, helping to address any shortfall that may arise. As noted above, Scotland Park is anticipated to be capable of delivering approximately 200 dwellings per annum once the C2C infrastructure is established, thereby making a meaningful contribution to housing supply during the Plan period. Alongside the C2C it has existing infrastructure, meaning that housing can be delivered more quickly.

2.3.7 The provision of another additional new settlement, which benefits from the sustainable transport hub due to C2C, will ensure that the Local Plan can deliver the amount of housing required to ensure a consistent supply during the entire Plan Period thereby making the Plan 'sound' as per the NPPF definition. Accordingly, Scotland Park should be identified as an additional allocation in the Local Plan.

2.4 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs

2.4.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.4.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Space Needs (prepared by Iceni in March 2025)⁵. The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace and that these locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide the "optimum locations" (paragraph 7.21).

2.4.3 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.4.4 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.4.5 Notwithstanding the above, Scotland Park is ideally located to support commercial, warehouse and logistic uses, as illustrated in the Vision Document which allows for a 26ha for Business Hub. There is already an existing B8 use on the Site, which can act as a catalyst to bring in more commercial uses. These commercial uses can help to open up the Site more sustainably.

2.4.6 Scotland Park is adjacent to the Strategic Road Network, benefits from on access directly to the A428, has an appropriate access road within the Site and, therefore, is considered to be an optimum location as set out in the Report. It is noted that the accessibility of the Site is likely to be further enhanced with the current upgrades to the A428 at Black Cat to Caxton Gibbet (due to be open in 2027)6, contributing towards the government's increasing emphasis on the Oxford to Cambridge Corridor. The delivery of an early phase of employment generating uses is considered appropriate and would act as a catalyst for the wider site to come forward.

2.4.7 The proposed allocations for industrial growth are focused on the accessibility to the A14, yet Greater Cambridge's own evidence points to the A428 as being an appropriate location, particularly as it is within the Oxford to Cambridge Corridor. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the A14. However, our client considers that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to the A428 provides a suitable alternative, particularly with the completion of the Black Cat to Caxton Gibbet improvements.

2.4.8 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and future residents of Scotland Park.

2.4.9 Therefore, the Site should be considered favourably for employment uses, as part of the overall Scotland Park development.

2.4.10 The Needs Assessment also states that there is a clear need for Mid Tech. Mid Tech comprises a mix of Class 'B' uses with larger office space. These types of uses support Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan period.

2.4.11 The Emerging Local Plan states that Mid Tech is an "emerging need" (paragraph 2.69). Mid Tech growth will be provided at Eddington and Cambridge East, with Cambourne delivering in the longer term (paragraph 2.69). However, these allocations do not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.4.12 Paragraph 7.22 of the 2025 Needs Assessment states:
"An additional edge of centre location with closer city proximity and links would be preferable, or ensuring enhanced connectivity to current and future proposals"
2.4.13 The Needs Assessment adds that the new phase at Eddington meets this requirement for Mid Tech. However, the recent approval granted at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Classe E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁷. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.4.14 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report, and it is crucial that alternative provision is made to support these Mid Tech uses. Scotland Park fully complies with Paragraph 7.22 of the 2025 Needs Assessment. It is considered to be an edge of centre location. The Illustrative Masterplan in the Vision Document, locates the Business Hub adjacent to the existing junction (Toft/Hardwick/Dry Drayton) access/egress. Therefore, it is considered to be suitable to support commercial uses, particularly Mid Tech.

2.4.15 Emerging Policy S/CE (Cambridge East) states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, including 20,000sqm (GIA) of B2/B8 space for both Mid Tech and general industrial uses.

2.4.16 As housing is set to be delivered from 2032, it is considered that the earliest employment space could be delivered is also from 2032. It is clear that there is a shortfall in Mid Tech employment space in the early years of the Local Plan. This is acknowledged in the 2025 Report (paragraph 7.22), which states:

"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period, which would not meet shorter term demand"

2.4.17 Therefore, there is a contradiction between the Greater Cambridge Local Plan and the evidence behind it with regard to the immediate need for Mid Tech.

2.4.18 Paragraph 7.22 of the 2025 Report further states that Mid Tech development should

ensure enhanced connectivity. Thanks to the provision of the Scotland Farm Sustainable Transport Hub and the proximity of the new settlement to Cambridge, it is considered that the Site adheres to these criteria.

2.4.19 In conclusion, the evidence behind the emerging Local Plan sets out a need for additional employment space to support Mid Tech uses and warehousing and distribution facilities in alternative locations. The 2025 Report provides criteria on the ideal location for a new Mid Tech location. The Site is ideally located to support Greater Cambridge's ambitions to support its knowledge intensive sectors, and it should therefore be allocated for residential-led mixed-use development in future iterations of the Local Plan.

2.5 Emerging Policy S/GB - The Green Belt

2.5.1 There have been no changes to the text surrounding emerging Policy S/GB since the Regulation 18 version of the Local Plan.

2.5.2 As stated in our client's representations to the Regulation 18 Local Plan, the land to the east of Scotland Farm, although within the new settlement, is located within the Green Belt. The land within the Green Belt equates to approximately 30% of the overall Site. It should therefore be noted that the majority of the Site is not within the Green Belt, although it is acknowledged that the land to the east of Scotland Road is required to support the delivery of both the Scotland Farm Transport Hub and additional development as part of the new settlement.

2.5.3 The new travel hub for C2C is located in Parcel HA2 and the remainder in a huge Outern Area Parcel (OA11), comprising 1,375.13ha.

2.5.4 As the sustainable travel hub is located in Parcel HA2, our client considers that the Site is suitable to support a sustainable new settlement as it benefits from proximity to the sustainable Travel Hub. The Vision Document that accompanied the Regulation 18 representations, set out suitable landscape mitigation to reduce the impact on the wider landscape.

2.5.5 As part of its Regulation 18 representations, our client provided justification that the Site falls within the definition of Grey Belt as set out in national policy, and should, therefore be designated as part of the emerging Local Plan.

2.5.6 The previous 2021 Green Belt Assessment⁸ concluded that the Parcels above 'strongly' contributed to purposes to the Green Belt (as set out in Paragraph 148 of the 2024 NPPF), with a focus on the merging of settlements.

2.5.7 In 2026, the Council published an updated Green Belt Assessment. The aim of this assessment was to identify sites that could be considered as Grey Belt.

2.5.8 The assessment notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 3.14).

2.5.9 The findings of the July 2026 Green Belt Assessment in relation to Parcels HA2 and OA11 are set out in the table below:

Table 2.1: Conclusions on Parcels HA2, and OA11 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

2.5.10 Our client however considers that the assessment of land's contribution to the purposes of the Green Belt should be considered on its own merits, rather than assessing significantly sized parcels. Parcel HA2 has already been considered suitable for release as it will accommodate the new sustainable transport hub and therefore, the conclusions set out in the updated 2026 Assessment are considered out of date.

2.5.11 The assessment of Parcel OA11 is therefore inappropriate and the findings are inaccurate. The Vision Document (Appendix 2 of the Regulation 18 representations) provides mitigation that reduces that impact.

2.5.12 Therefore, it is considered that the Site is considered suitable for development as 'Grey Belt' and should be allocated in the emerging Local Plan as it is in accordance with Paragraph 148 of the 2024 NPPF.

2.5.13 As our client considers that the Site falls within the definition of Grey Belt, it has been considered against the criteria set out in Paragraph 155 of the NPPF, which have been carried forward in Policies GB7 and GB8 of the 2026 NPPF, detailed below. It is noted that the criteria below are only relevant to the determination of planning applications. However, it demonstrates the suitability of the Site as a proposed new settlement in the emerging Local Plan.
a) The development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan

2.5.14 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan. The size of the Green Belt land extends to approximately 120ha and represents 0.5% of the Green Belt when compared with the overall Green Belt (26,090ha) of Cambridge¹⁰. If the size of the proposed sustainable Travel Hub were to be removed, given that it has already been approved in the TWAO, then the amount of land to be removed to support the sustainable new settlement represents only 0.4% of the Green Belt.

2.5.15 In addition, as stated in the Vision Document, the development of the Site would provide 160ha of public open space, with a large amount within the Green Belt itself. This includes the provision of greenway corridors to the east of the Site. The landscaping mitigates the impact of the development, thereby not undermining the purposes of the remaining Green Belt and contributing positively the overall landscape in accordance with Paragraph 159 of the 2024 NPPF.

2.5.16 As the Site represents just 0.5% of the Green Belt in Greater Cambridge, and only 0.4% if the Sustainable Travel Hub is removed, and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.

b) There is a demonstrable unmet need for the type of development proposed 2.5.17 As stated above, our client considers that the is a demonstrable need for additional, sustainable new settlements with locational benefits adjacent to approved strategic transport infrastructure.

2.5.18 Therefore, it is considered that these representations have demonstrated that there is a demonstrable unmet need for additional housing to support the Local Plan.
c) The development would be in a sustainable location, with particular reference to paragraphs 110 and 115 of this Framework

2.5.19 As previously stated, the Site incorporates the Scotland Farm Sustainable Transport Hub. The Vision Document also shows how Scotland Park has been designed to be a walkable settlement, comprising linked villages focused on the central Town Centre Hub. The Town Centre hub includes community facilities, such as schools, retail, leisure and health uses.

2.5.20 Therefore, the Site is in accordance with Paragraph 119 of the 2024 NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel and can be accessed by sustainable transport modes.

d) Where applicable, the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

2.5.21 The Site's response to the 'Golden Rules' is set out below:
a) Affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework or (ii) until such policies are in place, the policy set out in paragraph 157 below.

2.5.22 Paragraph 157 seeks a 50% affordable housing provision prior to the adoption of the new Local Plan. As the Site seeks to be an allocation in the emerging Local Plan, it should be considered against part (i).

2.5.23 Emerging Policy H/AH: Affordable Housing states that major sites should be seeking 40% affordable housing. Table 6 of the emerging Local Plan provides the affordable housing tenures for 15 or more dwellings.

2.5.24 Our client is committed to the provision of affordable housing as part of the overall housing delivery on the Site.
b) Necessary improvements to local or national infrastructure

2.5.25 Scotland Park already benefits from high-quality existing infrastructure or infrastructure that has been committed (e.g. its adjacency to the A428 junction, the availability of power supply and drainage, and the future provision of the Scotland Farm Sustainable Transport Hub).

2.5.26 Despite the above, the Vision Document states that the new settlement will provide land for new local infrastructure. Our client would be willing to discuss the requirements in greater detail with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.5.27 It is clear that the development will generate a need for contributions as well as the provision of the land in respect of (inter alia) healthcare, education, employment and skills and transport. Our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations but, as stated, above, is willing to provide the land to support these necessary facilities, such as the schools.

2.5.28 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).

c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.5.29 The Vision Document highlights the importance as providing open space not just to support new residents but residents in nearby settlements.

2.5.30 The Vision Document states that the new settlement is a landscape-led development, creating up to 160 hectares of newly publicly accessible green spaces. The Vision Document also sets out a network of greenway corridors, providing attractive and safe pedestrian routes through the development. The Vision Document further notes that other public open spaces includes sport pitches, community allotments and a community orchard. Therefore, it is clear that the proposed new settlement accords with part c) of the NPPF paragraph 156.

2.5.31 In conclusion, our client considers that significant parts of the Site meet the definition of Grey Belt as set out in national policy and that the Council's strategic parcel-based assessment does not adequately reflect either the approved Scotland Farm Sustainable Transport Hub or the Site's wider role in supporting sustainable growth. The Site benefits from a unique combination of committed strategic transport infrastructure, the ability to deliver a substantial amount of housing, extensive green infrastructure and supporting community facilities. As such, Scotland Park represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge. Its allocation would not only make a significant contribution towards meeting housing needs, but would also improve the resilience, flexibility and effectiveness of the emerging Local Plan by providing an additional growth location capable of delivering homes alongside infrastructure at an early stage in the Plan period. Accordingly, Scotland Park should be identified as a proposed allocation within the emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF. In particular, the Plan has failed to adequately consider Scotland Park as a reasonable alternative growth option and places significant reliance on ambitious delivery assumptions associated with a small number of strategic allocations.

3.1.2 The Plan relies on new settlements, which are dependent on large pieces of infrastructure being delivered, such as CSET, which have not yet been approved. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. Therefore, the housing trajectory is subject to material delivery risk. In contrast, Scotland Park benefits from the approved C2C scheme and associated Scotland Farm Sustainable Transport Hub, providing a significantly greater degree of certainty regarding the delivery of strategic transport infrastructure and supporting a more resilient approach to housing delivery. Scotland Farm benefits from high quality existing infrastructure, such as its proximity to the A428 junction and power, meaning it can be delivered more quickly.

3.1.3 Our client also has concerns over the deliverability of the new settlements to provide more than 200 dwellings per annum, which is considered a more realistic delivery assumption than set out in the latest Lichfield's start to finish report. Consequently, there is a realistic prospect that housing delivery could fall below the levels assumed within the Council's trajectory.

3.1.4 Therefore, the emerging Local Plan should identify additional sustainable growth opportunities capable of strengthening the resilience and flexibility of the development strategy and providing greater confidence that housing needs can be met throughout the Plan period.

3.1.5 The evidence behind the emerging Local Plan notes that there is a need for additional Mid Tech space, and the focus for logistics is on the A14 corridor. Whilst Eddington will make an important contribution, it remains unclear whether the proposed employment allocations will fully address the identified requirement for Mid Tech floorspace. The Site is ideally located as it is adjacent to the Strategic Road Network and can take advantage of the Scotland Farm Sustainable Transport Hub. Its location means that it can take advantage of the government's emphasis on the Oxford to Cambridge Corridor.

3.1.6 Scotland Park therefore represents a logical location to accommodate additional employment growth, including warehousing and logistics, alongside the delivery of housing and supporting infrastructure. There is already an existing B8 use onsite, which can act as a catalyst for more commercial growth, which can open up the Site more sustainably.

3.1.7 Our client maintains that the updated Green Belt evidence base does not adequately reflect the site-specific circumstances at Scotland Park, as it considers large Green Belt parcels, rather than assessing the Site on its own merits. In particular, insufficient regard has been had to the approved Scotland Farm Sustainable Transport Hub and the changed planning context arising from the approved C2C scheme. The Site clearly falls within the definition of Grey Belt.

3.1.8 The proposed new settlement, Scotland Park, provides a suitable additional allocation. As it is a new settlement, it will incorporate a range of services and facilities, within walking distance, including primary and secondary schools as well as the Scotland Farm Sustainable Transport Hub. The Site benefits from a unique combination of committed transport infrastructure, substantial housing capacity, employment opportunities, community infrastructure and extensive public open space. As such, it represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge and would materially strengthen the justification, effectiveness and overall resilience of the emerging Local Plan.

3.1.9 Accordingly, our client requests that the Local Plan is modified to allocate Scotland Park as a strategic mixed-use new settlement, comprising approximately 10,000 homes, employment land, supporting infrastructure, community facilities and extensive public open space, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map. Such an allocation would provide additional flexibility within the development strategy and improve confidence that Greater Cambridge's housing and employment needs can be met throughout the Plan period.

3.1.10 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.


Footnotes:
1 cambourne-to-cambridge-decision-letter.pdf
2 Housing Delivery Study Addendum 2026-06-30
3 Cambridge Housing Delivery Study Addendum October 2025
4 start-to-finish-3 how-quickly-do-large-scale-housing-sites-deliver.pdf
5 EBGCLPIWSSMar25v1Mar25 0.pdf
6 A428 Black Cat to Caxton Gibbet improvements - National Highways
7 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf
8 Greater Cambridge Green Belt Assessment
9 Greater Cambridge Green Belt Assessment
10 https://www.gov.uk/government/statistics/localauthority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

[Please refer to the submission attachments for the appendices.]

Appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF

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

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of PX Land Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 These representations build on those submitted by our client in response to the Regulation 18 Local Plan Consultation. As set out in those earlier representations, our client is the sole landowner of Scotland Farm, Scotland Road, Dry Drayton, Cambridgeshire ('the Site'). The Site forms part of the wider Scotland Park proposal and is referred to on that basis throughout these representations. A location plan of the Site is shown at Appendix 1.

1.1.3 Alongside the response to the Regulation 18 Consultation, the Site has been promoted by PX Land Ltd during the Calls for Sites process. Scotland Park was promoted as a new sustainable settlement comprising:
• 10,000 new homes (market and affordable housing).
• 160 hectares (ha) of public open space.
• 10ha for a town centre hub.
• Scotland Farm Sustainable Transport Hub to support the Cambourne to Cambridge Busway.
• 26ha for a business hub; and
• 20ha for education purposes (comprising one secondary school and up to four primary schools).

1.1.4 Since the publication of the Regulation 18 representations in January 2026, the Cambourne to Cambridge Busway was approved in September 2026¹. This includes the provision of the Scotland Farm Sustainable Transport Hub, which is within the boundary of the Scotland Park new settlement.

1.1.5 These representations follow on and supplement the representations submitted as part of the Regulation 18 Consultation. For completeness, the submitted representations are provided at Appendix 2. Details on the Site physical and planning context and PX Land is set out in the Regulation 18 representations; these have not been repeated as part of these representations for brevity.

1.1.6 However, our client is currently in discussion with a number of delivery partners for both housing and commercial sectors. They are also in contract with a motorway service station provider. Our client in conjunction with these partners is investigating suitability of the delivery of early parcel within the new settlement. They have also had interests from renewable energy providers due the ability of these providers to be able to easily plug into the existing infrastructure.

1.2 Regulation 19 Consultation

1.2.1 The Regulation 19 consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 For the Plan to be 'sound', it must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a revised NPPF was published in August 2026, it is understood that the Greater Cambridge Shared Planning Service intends to submit the emerging Local Plan to the Inspectorate in December 2026. Accordingly, and having regard to Appendix A of the 2026 NPPF, our client accepts that the Plan will be assessed against the 2024 NPPF.

1.2.3 Paragraph 36 states that a Local Plan must be:

a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.

c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.

d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

1.2.4 Our client does not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.2.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of its publication. In this context, our client strongly contends that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to the proposed development in the context of the Regulation 19 Pre-Submission Local Plan.

2.1.2 Our client has examined the housing delivery forecast that has been calculated as part of the AECOM 2026 Addendum² against the previous forecast provided as part of the Regulation 18 consultation in January 2026³ and has concerns about the Plan being able to ensure constant delivery throughout the Plan Period.

2.1.3 Our client has also analysed the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our client does not consider that Greater Cambridge has allocated a sufficient amount of commercial land to support Greater Cambridge's ambitions for growth, particularly with regard to Mid Tech accommodation.

2.2 Overreliance on New Settlements that lack Strategic Infrastructure

2.2.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations with 28% of housing delivery on the edge of Cambridge, 43% at new settlements and with rural areas accounting for approximately 14% (paragraph 3.2.93). It adds that the majority of development is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.2.2 The Addendum further states that new allocations will be phased from 2033/34 onwards following completion of the Grafham Water Supply Transfer and the delivery of other supporting infrastructure. Whilst our client acknowledges the position, it has concerns regarding the extent to which both allocations can be relied upon given their dependence on the timely delivery of key pieces of infrastructure. These allocations are considered in further detail below.

Grange Farm New Settlement

2.2.3 The Addendum states that the Grange Farm new settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure to unlock the Site for development is the delivery of the Cambridge South East Transport (CSET) Phase 2 Scheme.

2.2.4 CSET would provide a new busway between a new A11 travel hub and Cambridge

Biomedical Campus.

2.2.5 The delivery of CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of CSET are yet to be determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Therefore, our client considers that first completions in 2034/35 is unrealistic, as significant infrastructure is required to be in place prior to delivery of new homes. Any delay in the delivery of CSET, or other associated sustainable transport infrastructure projects, will inevitably delay the delivery of housing completely or limit the number of new homes in the initial phase.

2.2.6 In contrast, Scotland Park includes the sustainable travel hub, which has been located to support the Cambourne to Cambridge Busway (C2C), which is in PX Farms ownership. Scotland Park was chosen as the appropriate location for a Travel Hub given its easy access to the A428 and its low environmental sensitivity, despite it being located in the Cambridge Green Belt.

2.2.7 The Travel Hub has been designed to accommodate 2,000 car parking spaces, 300 cycle parking spaces and other facilities, such as a building and specialised LED lighting. Once completed, it is anticipated that there will be buses every 10 minutes from Cambourne to Cambridge.

2.2.8 C2C has been granted a Transport and Works Act Order (TWAO). It is anticipated that construction will be completed between January 2027 and December 2030. As the Order has already been approved, fully funded by the Greater Cambridge Partnership, it is considered that the delivery of a new settlement at PX Farms is a preferable location than the proposed new settlement at Grange Farm.

2.2.9 Paragraph 77 of the NPPF (2024) states:
"The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements. provided that they are well located and designed and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes"

2.2.10 Our client also notes that the delivery of Bourn Airfield is limited to 500 dwellings until C2C is delivered. Although the circumstances at Grange Farm are not identical, this further illustrates dependencies in the Council's spatial strategy on strategic transport that have not been approved, which consequential implications for the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET, therefore, represents a material risk to the assume delivery of 2,550 dwellings at Grange Farm during the Plan Period.

2.2.11 As C2C has already been granted consent through the TWAO, Scotland Park is considered to meet the criteria set out in 2024 NPPF Paragraph 77, unlike Grange Farm. The TWAO also includes new and enhanced public rights of way, leading into Cambridge, thereby providing a genuine choice of transport modes for future residents, in line with the NPPF.

2.2.12 Scotland Park therefore represents a credible and sustainable location for future growth which benefits from a higher degree of certainty regarding the delivery of key strategic transport infrastructure. Given that C2C is expected to be operational in advance of first occupations, the Site has the potential to support housing delivery earlier in the Plan period and with less reliance on the future delivery of major infrastructure projects. In this regard, Scotland Park represents an opportunity to strengthen the resilience and flexibility of the emerging Local Plan's development strategy and should be allocated for mixed-use development in future iterations of the Local Plan.

Cambourne North

2.2.13 Cambourne North is reliant on the delivery of two key pieces of transport-related infrastructure, namely C2C and East West Rail. As stated above, our client acknowledges that C2C has been approved. However, it is understood that the Highways Authority does not consider the delivery of East West Rail to be an automatic prerequisite to the commencement of housing development at Cambourne North, and as a minimum would require certainty on the timeframe for opening of the station. Our client therefore questions whether the allocation of Cambourne North is appropriate, especially given that C2C is also required to support the allocation in the current Local Plan of West Cambourne (2,350 additional homes granted in 2017 under Council reference: S/6438/07/O).

2.2.14 As highlighted in our client's Regulation 18 representations, there are no guarantees that a future government would be as committed to East West Rail as the current incumbent. Therefore, and to ensure resilience in its spatial strategy and housing delivery, the emerging Local Plan should identify growth at locations which benefit from committed strategic transport projects, including at Scotland Park.

2.2.15 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to significant infrastructure and timing risks. Whilst our client does not suggest that these locations will not come forward, the degree of reliance placed upon them introduces a level of delivery risk within the housing trajectory. In this context, Scotland Park should be considered as an additional allocation within the emerging Local Plan. Benefitting from the approved C2C scheme and associated Sustainable Transport Hub, the Site has the potential to provide a more immediate and infrastructure-led growth opportunity, thereby strengthening the resilience, flexibility and effectiveness of the Local Plan's overall development strategy. It is also adjacent to existing infrastructure, off the A428 Junction and has other infrastructure capabilities that can be utilised immediately, such as power. Therefore, Scotland Farm is considered to be more deliverable than the other proposed new settlements as it can be delivered without relying on the delivery of significant infrastructure. The Site's location also means that it can take advantage of the Government's emphasis on the Oxford to Cambridge Corridor.

2.3 Concerns over the delivery of proposed allocations contributing to the Local Plan Headroom

2.3.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). The Addendum continues to state that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding the new settlements that have been allocated (paragraph 3.2.76).

2.3.2 The headroom figure is reliant on the delivery of the new settlements, which are delivered later in the Plan Period, once the infrastructure is provided, such as CSET. Therefore, it is considered that additional housing should be provided to ensure resilience and that the headroom is maintained.

2.3.3 The 2026 Addendum further states that by the end of the Plan period, Grange Farm and Cambourne North are proposed to deliver up to 300 dwellings per annum and Cambridge East, up to 350 dwellings per annum.

2.3.4 Our client's Regulation 18 representations noted that the average housing delivery on sites of 5,000 dwellings or larger was substantially below 300 dwellings per annum, as set out in the latest Lichfields Start to Finish Report (2024)⁴. Therefore, our client maintains that an assumed delivery figure of 200 dwellings per annum would be much more realistic. Although, this level of delivery would only be once the required infrastructure is established.

2.3.5 Therefore, if 200 dwellings per annum were to be delivered at the three new settlements, as opposed to 300 dwellings per annum assumed in the 2026 Addendum, then it would result in a shortfall of 2,850 dwellings - this is significant. In addition, Greater Cambridge already acknowledge that there is a shortfall of housing delivery at the end of Plan Period (p63 of the 2026 Addendum) against the standard methodology figure. The Addendum notes that this shortfall will likely be offset against over delivery in previous years, but as stated in these representations, there is a significant concern that the over delivery will simply not materialise.

2.3.6 Accordingly, Scotland Park has the potential to form part of a more robust and resilient spatial strategy, helping to address any shortfall that may arise. As noted above, Scotland Park is anticipated to be capable of delivering approximately 200 dwellings per annum once the C2C infrastructure is established, thereby making a meaningful contribution to housing supply during the Plan period. Alongside the C2C it has existing infrastructure, meaning that housing can be delivered more quickly.

2.3.7 The provision of another additional new settlement, which benefits from the sustainable transport hub due to C2C, will ensure that the Local Plan can deliver the amount of housing required to ensure a consistent supply during the entire Plan Period thereby making the Plan 'sound' as per the NPPF definition. Accordingly, Scotland Park should be identified as an additional allocation in the Local Plan.

2.4 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs

2.4.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.4.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Space Needs (prepared by Iceni in March 2025)⁵. The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace and that these locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide the "optimum locations" (paragraph 7.21).

2.4.3 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.4.4 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.4.5 Notwithstanding the above, Scotland Park is ideally located to support commercial, warehouse and logistic uses, as illustrated in the Vision Document which allows for a 26ha for Business Hub. There is already an existing B8 use on the Site, which can act as a catalyst to bring in more commercial uses. These commercial uses can help to open up the Site more sustainably.

2.4.6 Scotland Park is adjacent to the Strategic Road Network, benefits from on access directly to the A428, has an appropriate access road within the Site and, therefore, is considered to be an optimum location as set out in the Report. It is noted that the accessibility of the Site is likely to be further enhanced with the current upgrades to the A428 at Black Cat to Caxton Gibbet (due to be open in 2027)6, contributing towards the government's increasing emphasis on the Oxford to Cambridge Corridor. The delivery of an early phase of employment generating uses is considered appropriate and would act as a catalyst for the wider site to come forward.

2.4.7 The proposed allocations for industrial growth are focused on the accessibility to the A14, yet Greater Cambridge's own evidence points to the A428 as being an appropriate location, particularly as it is within the Oxford to Cambridge Corridor. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the A14. However, our client considers that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to the A428 provides a suitable alternative, particularly with the completion of the Black Cat to Caxton Gibbet improvements.

2.4.8 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and future residents of Scotland Park.

2.4.9 Therefore, the Site should be considered favourably for employment uses, as part of the overall Scotland Park development.

2.4.10 The Needs Assessment also states that there is a clear need for Mid Tech. Mid Tech comprises a mix of Class 'B' uses with larger office space. These types of uses support Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan period.

2.4.11 The Emerging Local Plan states that Mid Tech is an "emerging need" (paragraph 2.69). Mid Tech growth will be provided at Eddington and Cambridge East, with Cambourne delivering in the longer term (paragraph 2.69). However, these allocations do not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.4.12 Paragraph 7.22 of the 2025 Needs Assessment states:
"An additional edge of centre location with closer city proximity and links would be preferable, or ensuring enhanced connectivity to current and future proposals"
2.4.13 The Needs Assessment adds that the new phase at Eddington meets this requirement for Mid Tech. However, the recent approval granted at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Classe E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁷. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.4.14 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report, and it is crucial that alternative provision is made to support these Mid Tech uses. Scotland Park fully complies with Paragraph 7.22 of the 2025 Needs Assessment. It is considered to be an edge of centre location. The Illustrative Masterplan in the Vision Document, locates the Business Hub adjacent to the existing junction (Toft/Hardwick/Dry Drayton) access/egress. Therefore, it is considered to be suitable to support commercial uses, particularly Mid Tech.

2.4.15 Emerging Policy S/CE (Cambridge East) states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, including 20,000sqm (GIA) of B2/B8 space for both Mid Tech and general industrial uses.

2.4.16 As housing is set to be delivered from 2032, it is considered that the earliest employment space could be delivered is also from 2032. It is clear that there is a shortfall in Mid Tech employment space in the early years of the Local Plan. This is acknowledged in the 2025 Report (paragraph 7.22), which states:

"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period, which would not meet shorter term demand"

2.4.17 Therefore, there is a contradiction between the Greater Cambridge Local Plan and the evidence behind it with regard to the immediate need for Mid Tech.

2.4.18 Paragraph 7.22 of the 2025 Report further states that Mid Tech development should

ensure enhanced connectivity. Thanks to the provision of the Scotland Farm Sustainable Transport Hub and the proximity of the new settlement to Cambridge, it is considered that the Site adheres to these criteria.

2.4.19 In conclusion, the evidence behind the emerging Local Plan sets out a need for additional employment space to support Mid Tech uses and warehousing and distribution facilities in alternative locations. The 2025 Report provides criteria on the ideal location for a new Mid Tech location. The Site is ideally located to support Greater Cambridge's ambitions to support its knowledge intensive sectors, and it should therefore be allocated for residential-led mixed-use development in future iterations of the Local Plan.

2.5 Emerging Policy S/GB - The Green Belt

2.5.1 There have been no changes to the text surrounding emerging Policy S/GB since the Regulation 18 version of the Local Plan.

2.5.2 As stated in our client's representations to the Regulation 18 Local Plan, the land to the east of Scotland Farm, although within the new settlement, is located within the Green Belt. The land within the Green Belt equates to approximately 30% of the overall Site. It should therefore be noted that the majority of the Site is not within the Green Belt, although it is acknowledged that the land to the east of Scotland Road is required to support the delivery of both the Scotland Farm Transport Hub and additional development as part of the new settlement.

2.5.3 The new travel hub for C2C is located in Parcel HA2 and the remainder in a huge Outern Area Parcel (OA11), comprising 1,375.13ha.

2.5.4 As the sustainable travel hub is located in Parcel HA2, our client considers that the Site is suitable to support a sustainable new settlement as it benefits from proximity to the sustainable Travel Hub. The Vision Document that accompanied the Regulation 18 representations, set out suitable landscape mitigation to reduce the impact on the wider landscape.

2.5.5 As part of its Regulation 18 representations, our client provided justification that the Site falls within the definition of Grey Belt as set out in national policy, and should, therefore be designated as part of the emerging Local Plan.

2.5.6 The previous 2021 Green Belt Assessment⁸ concluded that the Parcels above 'strongly' contributed to purposes to the Green Belt (as set out in Paragraph 148 of the 2024 NPPF), with a focus on the merging of settlements.

2.5.7 In 2026, the Council published an updated Green Belt Assessment. The aim of this assessment was to identify sites that could be considered as Grey Belt.

2.5.8 The assessment notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 3.14).

2.5.9 The findings of the July 2026 Green Belt Assessment in relation to Parcels HA2 and OA11 are set out in the table below:

Table 2.1: Conclusions on Parcels HA2, and OA11 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

2.5.10 Our client however considers that the assessment of land's contribution to the purposes of the Green Belt should be considered on its own merits, rather than assessing significantly sized parcels. Parcel HA2 has already been considered suitable for release as it will accommodate the new sustainable transport hub and therefore, the conclusions set out in the updated 2026 Assessment are considered out of date.

2.5.11 The assessment of Parcel OA11 is therefore inappropriate and the findings are inaccurate. The Vision Document (Appendix 2 of the Regulation 18 representations) provides mitigation that reduces that impact.

2.5.12 Therefore, it is considered that the Site is considered suitable for development as 'Grey Belt' and should be allocated in the emerging Local Plan as it is in accordance with Paragraph 148 of the 2024 NPPF.

2.5.13 As our client considers that the Site falls within the definition of Grey Belt, it has been considered against the criteria set out in Paragraph 155 of the NPPF, which have been carried forward in Policies GB7 and GB8 of the 2026 NPPF, detailed below. It is noted that the criteria below are only relevant to the determination of planning applications. However, it demonstrates the suitability of the Site as a proposed new settlement in the emerging Local Plan.
a) The development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan

2.5.14 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan. The size of the Green Belt land extends to approximately 120ha and represents 0.5% of the Green Belt when compared with the overall Green Belt (26,090ha) of Cambridge¹⁰. If the size of the proposed sustainable Travel Hub were to be removed, given that it has already been approved in the TWAO, then the amount of land to be removed to support the sustainable new settlement represents only 0.4% of the Green Belt.

2.5.15 In addition, as stated in the Vision Document, the development of the Site would provide 160ha of public open space, with a large amount within the Green Belt itself. This includes the provision of greenway corridors to the east of the Site. The landscaping mitigates the impact of the development, thereby not undermining the purposes of the remaining Green Belt and contributing positively the overall landscape in accordance with Paragraph 159 of the 2024 NPPF.

2.5.16 As the Site represents just 0.5% of the Green Belt in Greater Cambridge, and only 0.4% if the Sustainable Travel Hub is removed, and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.

b) There is a demonstrable unmet need for the type of development proposed 2.5.17 As stated above, our client considers that the is a demonstrable need for additional, sustainable new settlements with locational benefits adjacent to approved strategic transport infrastructure.

2.5.18 Therefore, it is considered that these representations have demonstrated that there is a demonstrable unmet need for additional housing to support the Local Plan.
c) The development would be in a sustainable location, with particular reference to paragraphs 110 and 115 of this Framework

2.5.19 As previously stated, the Site incorporates the Scotland Farm Sustainable Transport Hub. The Vision Document also shows how Scotland Park has been designed to be a walkable settlement, comprising linked villages focused on the central Town Centre Hub. The Town Centre hub includes community facilities, such as schools, retail, leisure and health uses.

2.5.20 Therefore, the Site is in accordance with Paragraph 119 of the 2024 NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel and can be accessed by sustainable transport modes.

d) Where applicable, the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

2.5.21 The Site's response to the 'Golden Rules' is set out below:
a) Affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework or (ii) until such policies are in place, the policy set out in paragraph 157 below.

2.5.22 Paragraph 157 seeks a 50% affordable housing provision prior to the adoption of the new Local Plan. As the Site seeks to be an allocation in the emerging Local Plan, it should be considered against part (i).

2.5.23 Emerging Policy H/AH: Affordable Housing states that major sites should be seeking 40% affordable housing. Table 6 of the emerging Local Plan provides the affordable housing tenures for 15 or more dwellings.

2.5.24 Our client is committed to the provision of affordable housing as part of the overall housing delivery on the Site.
b) Necessary improvements to local or national infrastructure

2.5.25 Scotland Park already benefits from high-quality existing infrastructure or infrastructure that has been committed (e.g. its adjacency to the A428 junction, the availability of power supply and drainage, and the future provision of the Scotland Farm Sustainable Transport Hub).

2.5.26 Despite the above, the Vision Document states that the new settlement will provide land for new local infrastructure. Our client would be willing to discuss the requirements in greater detail with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.5.27 It is clear that the development will generate a need for contributions as well as the provision of the land in respect of (inter alia) healthcare, education, employment and skills and transport. Our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations but, as stated, above, is willing to provide the land to support these necessary facilities, such as the schools.

2.5.28 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).

c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.5.29 The Vision Document highlights the importance as providing open space not just to support new residents but residents in nearby settlements.

2.5.30 The Vision Document states that the new settlement is a landscape-led development, creating up to 160 hectares of newly publicly accessible green spaces. The Vision Document also sets out a network of greenway corridors, providing attractive and safe pedestrian routes through the development. The Vision Document further notes that other public open spaces includes sport pitches, community allotments and a community orchard. Therefore, it is clear that the proposed new settlement accords with part c) of the NPPF paragraph 156.

2.5.31 In conclusion, our client considers that significant parts of the Site meet the definition of Grey Belt as set out in national policy and that the Council's strategic parcel-based assessment does not adequately reflect either the approved Scotland Farm Sustainable Transport Hub or the Site's wider role in supporting sustainable growth. The Site benefits from a unique combination of committed strategic transport infrastructure, the ability to deliver a substantial amount of housing, extensive green infrastructure and supporting community facilities. As such, Scotland Park represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge. Its allocation would not only make a significant contribution towards meeting housing needs, but would also improve the resilience, flexibility and effectiveness of the emerging Local Plan by providing an additional growth location capable of delivering homes alongside infrastructure at an early stage in the Plan period. Accordingly, Scotland Park should be identified as a proposed allocation within the emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF. In particular, the Plan has failed to adequately consider Scotland Park as a reasonable alternative growth option and places significant reliance on ambitious delivery assumptions associated with a small number of strategic allocations.

3.1.2 The Plan relies on new settlements, which are dependent on large pieces of infrastructure being delivered, such as CSET, which have not yet been approved. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. Therefore, the housing trajectory is subject to material delivery risk. In contrast, Scotland Park benefits from the approved C2C scheme and associated Scotland Farm Sustainable Transport Hub, providing a significantly greater degree of certainty regarding the delivery of strategic transport infrastructure and supporting a more resilient approach to housing delivery. Scotland Farm benefits from high quality existing infrastructure, such as its proximity to the A428 junction and power, meaning it can be delivered more quickly.

3.1.3 Our client also has concerns over the deliverability of the new settlements to provide more than 200 dwellings per annum, which is considered a more realistic delivery assumption than set out in the latest Lichfield's start to finish report. Consequently, there is a realistic prospect that housing delivery could fall below the levels assumed within the Council's trajectory.

3.1.4 Therefore, the emerging Local Plan should identify additional sustainable growth opportunities capable of strengthening the resilience and flexibility of the development strategy and providing greater confidence that housing needs can be met throughout the Plan period.

3.1.5 The evidence behind the emerging Local Plan notes that there is a need for additional Mid Tech space, and the focus for logistics is on the A14 corridor. Whilst Eddington will make an important contribution, it remains unclear whether the proposed employment allocations will fully address the identified requirement for Mid Tech floorspace. The Site is ideally located as it is adjacent to the Strategic Road Network and can take advantage of the Scotland Farm Sustainable Transport Hub. Its location means that it can take advantage of the government's emphasis on the Oxford to Cambridge Corridor.

3.1.6 Scotland Park therefore represents a logical location to accommodate additional employment growth, including warehousing and logistics, alongside the delivery of housing and supporting infrastructure. There is already an existing B8 use onsite, which can act as a catalyst for more commercial growth, which can open up the Site more sustainably.

3.1.7 Our client maintains that the updated Green Belt evidence base does not adequately reflect the site-specific circumstances at Scotland Park, as it considers large Green Belt parcels, rather than assessing the Site on its own merits. In particular, insufficient regard has been had to the approved Scotland Farm Sustainable Transport Hub and the changed planning context arising from the approved C2C scheme. The Site clearly falls within the definition of Grey Belt.

3.1.8 The proposed new settlement, Scotland Park, provides a suitable additional allocation. As it is a new settlement, it will incorporate a range of services and facilities, within walking distance, including primary and secondary schools as well as the Scotland Farm Sustainable Transport Hub. The Site benefits from a unique combination of committed transport infrastructure, substantial housing capacity, employment opportunities, community infrastructure and extensive public open space. As such, it represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge and would materially strengthen the justification, effectiveness and overall resilience of the emerging Local Plan.

3.1.9 Accordingly, our client requests that the Local Plan is modified to allocate Scotland Park as a strategic mixed-use new settlement, comprising approximately 10,000 homes, employment land, supporting infrastructure, community facilities and extensive public open space, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map. Such an allocation would provide additional flexibility within the development strategy and improve confidence that Greater Cambridge's housing and employment needs can be met throughout the Plan period.

3.1.10 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.


Footnotes:
1 cambourne-to-cambridge-decision-letter.pdf
2 Housing Delivery Study Addendum 2026-06-30
3 Cambridge Housing Delivery Study Addendum October 2025
4 start-to-finish-3 how-quickly-do-large-scale-housing-sites-deliver.pdf
5 EBGCLPIWSSMar25v1Mar25 0.pdf
6 A428 Black Cat to Caxton Gibbet improvements - National Highways
7 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf
8 Greater Cambridge Green Belt Assessment
9 Greater Cambridge Green Belt Assessment
10 https://www.gov.uk/government/statistics/localauthority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

[Please refer to the submission attachments for the appendices.]

Our client considers that significant parts of the Site meet the definition of Grey Belt as set out in national policy and that the Council's strategic parcel-based assessment does not adequately reflect either the approved Scotland Farm Sustainable Transport Hub or the Site's wider role in supporting sustainable growth. Its allocation would not only make a significant contribution towards meeting housing needs, but would also improve the resilience, flexibility and effectiveness of the emerging Local Plan by providing an additional growth location capable of delivering homes alongside infrastructure at an early stage in the Plan period. Accordingly, Scotland Park should be identified as a proposed allocation within the emerging Local Plan.

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

1 Introduction

1.1.1 These Regulation 19 representations have been prepared by Lanpro Services on behalf of PX Land Ltd ('our client'). The representations respond to Greater Cambridge's Regulation 19 Local Plan.

1.1.2 These representations build on those submitted by our client in response to the Regulation 18 Local Plan Consultation. As set out in those earlier representations, our client is the sole landowner of Scotland Farm, Scotland Road, Dry Drayton, Cambridgeshire ('the Site'). The Site forms part of the wider Scotland Park proposal and is referred to on that basis throughout these representations. A location plan of the Site is shown at Appendix 1.

1.1.3 Alongside the response to the Regulation 18 Consultation, the Site has been promoted by PX Land Ltd during the Calls for Sites process. Scotland Park was promoted as a new sustainable settlement comprising:
• 10,000 new homes (market and affordable housing).
• 160 hectares (ha) of public open space.
• 10ha for a town centre hub.
• Scotland Farm Sustainable Transport Hub to support the Cambourne to Cambridge Busway.
• 26ha for a business hub; and
• 20ha for education purposes (comprising one secondary school and up to four primary schools).

1.1.4 Since the publication of the Regulation 18 representations in January 2026, the Cambourne to Cambridge Busway was approved in September 2026¹. This includes the provision of the Scotland Farm Sustainable Transport Hub, which is within the boundary of the Scotland Park new settlement.

1.1.5 These representations follow on and supplement the representations submitted as part of the Regulation 18 Consultation. For completeness, the submitted representations are provided at Appendix 2. Details on the Site physical and planning context and PX Land is set out in the Regulation 18 representations; these have not been repeated as part of these representations for brevity.

1.1.6 However, our client is currently in discussion with a number of delivery partners for both housing and commercial sectors. They are also in contract with a motorway service station provider. Our client in conjunction with these partners is investigating suitability of the delivery of early parcel within the new settlement. They have also had interests from renewable energy providers due the ability of these providers to be able to easily plug into the existing infrastructure.

1.2 Regulation 19 Consultation

1.2.1 The Regulation 19 consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.2.2 For the Plan to be 'sound', it must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a revised NPPF was published in August 2026, it is understood that the Greater Cambridge Shared Planning Service intends to submit the emerging Local Plan to the Inspectorate in December 2026. Accordingly, and having regard to Appendix A of the 2026 NPPF, our client accepts that the Plan will be assessed against the 2024 NPPF.

1.2.3 Paragraph 36 states that a Local Plan must be:

a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

b) Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.

c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.

d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

1.2.4 Our client does not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.2.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of its publication. In this context, our client strongly contends that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.3 Structure of Document
1.3.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to the proposed development in the context of the Regulation 19 Pre-Submission Local Plan.

2.1.2 Our client has examined the housing delivery forecast that has been calculated as part of the AECOM 2026 Addendum² against the previous forecast provided as part of the Regulation 18 consultation in January 2026³ and has concerns about the Plan being able to ensure constant delivery throughout the Plan Period.

2.1.3 Our client has also analysed the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our client does not consider that Greater Cambridge has allocated a sufficient amount of commercial land to support Greater Cambridge's ambitions for growth, particularly with regard to Mid Tech accommodation.

2.2 Overreliance on New Settlements that lack Strategic Infrastructure

2.2.1 The 2026 Addendum acknowledges that there is a reliance on larger strategic allocations with 28% of housing delivery on the edge of Cambridge, 43% at new settlements and with rural areas accounting for approximately 14% (paragraph 3.2.93). It adds that the majority of development is from existing allocations that have outline planning permission and that two of the new settlements, Grange Farm and Cambourne North, will only contribute around 10% of the supply during the Plan Period (paragraph 3.2.94).

2.2.2 The Addendum further states that new allocations will be phased from 2033/34 onwards following completion of the Grafham Water Supply Transfer and the delivery of other supporting infrastructure. Whilst our client acknowledges the position, it has concerns regarding the extent to which both allocations can be relied upon given their dependence on the timely delivery of key pieces of infrastructure. These allocations are considered in further detail below.

Grange Farm New Settlement

2.2.3 The Addendum states that the Grange Farm new settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure to unlock the Site for development is the delivery of the Cambridge South East Transport (CSET) Phase 2 Scheme.

2.2.4 CSET would provide a new busway between a new A11 travel hub and Cambridge

Biomedical Campus.

2.2.5 The delivery of CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of CSET are yet to be determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Therefore, our client considers that first completions in 2034/35 is unrealistic, as significant infrastructure is required to be in place prior to delivery of new homes. Any delay in the delivery of CSET, or other associated sustainable transport infrastructure projects, will inevitably delay the delivery of housing completely or limit the number of new homes in the initial phase.

2.2.6 In contrast, Scotland Park includes the sustainable travel hub, which has been located to support the Cambourne to Cambridge Busway (C2C), which is in PX Farms ownership. Scotland Park was chosen as the appropriate location for a Travel Hub given its easy access to the A428 and its low environmental sensitivity, despite it being located in the Cambridge Green Belt.

2.2.7 The Travel Hub has been designed to accommodate 2,000 car parking spaces, 300 cycle parking spaces and other facilities, such as a building and specialised LED lighting. Once completed, it is anticipated that there will be buses every 10 minutes from Cambourne to Cambridge.

2.2.8 C2C has been granted a Transport and Works Act Order (TWAO). It is anticipated that construction will be completed between January 2027 and December 2030. As the Order has already been approved, fully funded by the Greater Cambridge Partnership, it is considered that the delivery of a new settlement at PX Farms is a preferable location than the proposed new settlement at Grange Farm.

2.2.9 Paragraph 77 of the NPPF (2024) states:
"The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements. provided that they are well located and designed and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes"

2.2.10 Our client also notes that the delivery of Bourn Airfield is limited to 500 dwellings until C2C is delivered. Although the circumstances at Grange Farm are not identical, this further illustrates dependencies in the Council's spatial strategy on strategic transport that have not been approved, which consequential implications for the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET, therefore, represents a material risk to the assume delivery of 2,550 dwellings at Grange Farm during the Plan Period.

2.2.11 As C2C has already been granted consent through the TWAO, Scotland Park is considered to meet the criteria set out in 2024 NPPF Paragraph 77, unlike Grange Farm. The TWAO also includes new and enhanced public rights of way, leading into Cambridge, thereby providing a genuine choice of transport modes for future residents, in line with the NPPF.

2.2.12 Scotland Park therefore represents a credible and sustainable location for future growth which benefits from a higher degree of certainty regarding the delivery of key strategic transport infrastructure. Given that C2C is expected to be operational in advance of first occupations, the Site has the potential to support housing delivery earlier in the Plan period and with less reliance on the future delivery of major infrastructure projects. In this regard, Scotland Park represents an opportunity to strengthen the resilience and flexibility of the emerging Local Plan's development strategy and should be allocated for mixed-use development in future iterations of the Local Plan.

Cambourne North

2.2.13 Cambourne North is reliant on the delivery of two key pieces of transport-related infrastructure, namely C2C and East West Rail. As stated above, our client acknowledges that C2C has been approved. However, it is understood that the Highways Authority does not consider the delivery of East West Rail to be an automatic prerequisite to the commencement of housing development at Cambourne North, and as a minimum would require certainty on the timeframe for opening of the station. Our client therefore questions whether the allocation of Cambourne North is appropriate, especially given that C2C is also required to support the allocation in the current Local Plan of West Cambourne (2,350 additional homes granted in 2017 under Council reference: S/6438/07/O).

2.2.14 As highlighted in our client's Regulation 18 representations, there are no guarantees that a future government would be as committed to East West Rail as the current incumbent. Therefore, and to ensure resilience in its spatial strategy and housing delivery, the emerging Local Plan should identify growth at locations which benefit from committed strategic transport projects, including at Scotland Park.

2.2.15 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to significant infrastructure and timing risks. Whilst our client does not suggest that these locations will not come forward, the degree of reliance placed upon them introduces a level of delivery risk within the housing trajectory. In this context, Scotland Park should be considered as an additional allocation within the emerging Local Plan. Benefitting from the approved C2C scheme and associated Sustainable Transport Hub, the Site has the potential to provide a more immediate and infrastructure-led growth opportunity, thereby strengthening the resilience, flexibility and effectiveness of the Local Plan's overall development strategy. It is also adjacent to existing infrastructure, off the A428 Junction and has other infrastructure capabilities that can be utilised immediately, such as power. Therefore, Scotland Farm is considered to be more deliverable than the other proposed new settlements as it can be delivered without relying on the delivery of significant infrastructure. The Site's location also means that it can take advantage of the Government's emphasis on the Oxford to Cambridge Corridor.

2.3 Concerns over the delivery of proposed allocations contributing to the Local Plan Headroom

2.3.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). The Addendum continues to state that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding the new settlements that have been allocated (paragraph 3.2.76).

2.3.2 The headroom figure is reliant on the delivery of the new settlements, which are delivered later in the Plan Period, once the infrastructure is provided, such as CSET. Therefore, it is considered that additional housing should be provided to ensure resilience and that the headroom is maintained.

2.3.3 The 2026 Addendum further states that by the end of the Plan period, Grange Farm and Cambourne North are proposed to deliver up to 300 dwellings per annum and Cambridge East, up to 350 dwellings per annum.

2.3.4 Our client's Regulation 18 representations noted that the average housing delivery on sites of 5,000 dwellings or larger was substantially below 300 dwellings per annum, as set out in the latest Lichfields Start to Finish Report (2024)⁴. Therefore, our client maintains that an assumed delivery figure of 200 dwellings per annum would be much more realistic. Although, this level of delivery would only be once the required infrastructure is established.

2.3.5 Therefore, if 200 dwellings per annum were to be delivered at the three new settlements, as opposed to 300 dwellings per annum assumed in the 2026 Addendum, then it would result in a shortfall of 2,850 dwellings - this is significant. In addition, Greater Cambridge already acknowledge that there is a shortfall of housing delivery at the end of Plan Period (p63 of the 2026 Addendum) against the standard methodology figure. The Addendum notes that this shortfall will likely be offset against over delivery in previous years, but as stated in these representations, there is a significant concern that the over delivery will simply not materialise.

2.3.6 Accordingly, Scotland Park has the potential to form part of a more robust and resilient spatial strategy, helping to address any shortfall that may arise. As noted above, Scotland Park is anticipated to be capable of delivering approximately 200 dwellings per annum once the C2C infrastructure is established, thereby making a meaningful contribution to housing supply during the Plan period. Alongside the C2C it has existing infrastructure, meaning that housing can be delivered more quickly.

2.3.7 The provision of another additional new settlement, which benefits from the sustainable transport hub due to C2C, will ensure that the Local Plan can deliver the amount of housing required to ensure a consistent supply during the entire Plan Period thereby making the Plan 'sound' as per the NPPF definition. Accordingly, Scotland Park should be identified as an additional allocation in the Local Plan.

2.4 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs

2.4.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.4.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Space Needs (prepared by Iceni in March 2025)⁵. The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace and that these locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide the "optimum locations" (paragraph 7.21).

2.4.3 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.4.4 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.4.5 Notwithstanding the above, Scotland Park is ideally located to support commercial, warehouse and logistic uses, as illustrated in the Vision Document which allows for a 26ha for Business Hub. There is already an existing B8 use on the Site, which can act as a catalyst to bring in more commercial uses. These commercial uses can help to open up the Site more sustainably.

2.4.6 Scotland Park is adjacent to the Strategic Road Network, benefits from on access directly to the A428, has an appropriate access road within the Site and, therefore, is considered to be an optimum location as set out in the Report. It is noted that the accessibility of the Site is likely to be further enhanced with the current upgrades to the A428 at Black Cat to Caxton Gibbet (due to be open in 2027)6, contributing towards the government's increasing emphasis on the Oxford to Cambridge Corridor. The delivery of an early phase of employment generating uses is considered appropriate and would act as a catalyst for the wider site to come forward.

2.4.7 The proposed allocations for industrial growth are focused on the accessibility to the A14, yet Greater Cambridge's own evidence points to the A428 as being an appropriate location, particularly as it is within the Oxford to Cambridge Corridor. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the A14. However, our client considers that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to the A428 provides a suitable alternative, particularly with the completion of the Black Cat to Caxton Gibbet improvements.

2.4.8 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and future residents of Scotland Park.

2.4.9 Therefore, the Site should be considered favourably for employment uses, as part of the overall Scotland Park development.

2.4.10 The Needs Assessment also states that there is a clear need for Mid Tech. Mid Tech comprises a mix of Class 'B' uses with larger office space. These types of uses support Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan period.

2.4.11 The Emerging Local Plan states that Mid Tech is an "emerging need" (paragraph 2.69). Mid Tech growth will be provided at Eddington and Cambridge East, with Cambourne delivering in the longer term (paragraph 2.69). However, these allocations do not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.4.12 Paragraph 7.22 of the 2025 Needs Assessment states:
"An additional edge of centre location with closer city proximity and links would be preferable, or ensuring enhanced connectivity to current and future proposals"
2.4.13 The Needs Assessment adds that the new phase at Eddington meets this requirement for Mid Tech. However, the recent approval granted at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Classe E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁷. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.4.14 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report, and it is crucial that alternative provision is made to support these Mid Tech uses. Scotland Park fully complies with Paragraph 7.22 of the 2025 Needs Assessment. It is considered to be an edge of centre location. The Illustrative Masterplan in the Vision Document, locates the Business Hub adjacent to the existing junction (Toft/Hardwick/Dry Drayton) access/egress. Therefore, it is considered to be suitable to support commercial uses, particularly Mid Tech.

2.4.15 Emerging Policy S/CE (Cambridge East) states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, including 20,000sqm (GIA) of B2/B8 space for both Mid Tech and general industrial uses.

2.4.16 As housing is set to be delivered from 2032, it is considered that the earliest employment space could be delivered is also from 2032. It is clear that there is a shortfall in Mid Tech employment space in the early years of the Local Plan. This is acknowledged in the 2025 Report (paragraph 7.22), which states:

"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period, which would not meet shorter term demand"

2.4.17 Therefore, there is a contradiction between the Greater Cambridge Local Plan and the evidence behind it with regard to the immediate need for Mid Tech.

2.4.18 Paragraph 7.22 of the 2025 Report further states that Mid Tech development should

ensure enhanced connectivity. Thanks to the provision of the Scotland Farm Sustainable Transport Hub and the proximity of the new settlement to Cambridge, it is considered that the Site adheres to these criteria.

2.4.19 In conclusion, the evidence behind the emerging Local Plan sets out a need for additional employment space to support Mid Tech uses and warehousing and distribution facilities in alternative locations. The 2025 Report provides criteria on the ideal location for a new Mid Tech location. The Site is ideally located to support Greater Cambridge's ambitions to support its knowledge intensive sectors, and it should therefore be allocated for residential-led mixed-use development in future iterations of the Local Plan.

2.5 Emerging Policy S/GB - The Green Belt

2.5.1 There have been no changes to the text surrounding emerging Policy S/GB since the Regulation 18 version of the Local Plan.

2.5.2 As stated in our client's representations to the Regulation 18 Local Plan, the land to the east of Scotland Farm, although within the new settlement, is located within the Green Belt. The land within the Green Belt equates to approximately 30% of the overall Site. It should therefore be noted that the majority of the Site is not within the Green Belt, although it is acknowledged that the land to the east of Scotland Road is required to support the delivery of both the Scotland Farm Transport Hub and additional development as part of the new settlement.

2.5.3 The new travel hub for C2C is located in Parcel HA2 and the remainder in a huge Outern Area Parcel (OA11), comprising 1,375.13ha.

2.5.4 As the sustainable travel hub is located in Parcel HA2, our client considers that the Site is suitable to support a sustainable new settlement as it benefits from proximity to the sustainable Travel Hub. The Vision Document that accompanied the Regulation 18 representations, set out suitable landscape mitigation to reduce the impact on the wider landscape.

2.5.5 As part of its Regulation 18 representations, our client provided justification that the Site falls within the definition of Grey Belt as set out in national policy, and should, therefore be designated as part of the emerging Local Plan.

2.5.6 The previous 2021 Green Belt Assessment⁸ concluded that the Parcels above 'strongly' contributed to purposes to the Green Belt (as set out in Paragraph 148 of the 2024 NPPF), with a focus on the merging of settlements.

2.5.7 In 2026, the Council published an updated Green Belt Assessment. The aim of this assessment was to identify sites that could be considered as Grey Belt.

2.5.8 The assessment notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 3.14).

2.5.9 The findings of the July 2026 Green Belt Assessment in relation to Parcels HA2 and OA11 are set out in the table below:

Table 2.1: Conclusions on Parcels HA2, and OA11 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

2.5.10 Our client however considers that the assessment of land's contribution to the purposes of the Green Belt should be considered on its own merits, rather than assessing significantly sized parcels. Parcel HA2 has already been considered suitable for release as it will accommodate the new sustainable transport hub and therefore, the conclusions set out in the updated 2026 Assessment are considered out of date.

2.5.11 The assessment of Parcel OA11 is therefore inappropriate and the findings are inaccurate. The Vision Document (Appendix 2 of the Regulation 18 representations) provides mitigation that reduces that impact.

2.5.12 Therefore, it is considered that the Site is considered suitable for development as 'Grey Belt' and should be allocated in the emerging Local Plan as it is in accordance with Paragraph 148 of the 2024 NPPF.

2.5.13 As our client considers that the Site falls within the definition of Grey Belt, it has been considered against the criteria set out in Paragraph 155 of the NPPF, which have been carried forward in Policies GB7 and GB8 of the 2026 NPPF, detailed below. It is noted that the criteria below are only relevant to the determination of planning applications. However, it demonstrates the suitability of the Site as a proposed new settlement in the emerging Local Plan.
a) The development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan

2.5.14 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the Plan. The size of the Green Belt land extends to approximately 120ha and represents 0.5% of the Green Belt when compared with the overall Green Belt (26,090ha) of Cambridge¹⁰. If the size of the proposed sustainable Travel Hub were to be removed, given that it has already been approved in the TWAO, then the amount of land to be removed to support the sustainable new settlement represents only 0.4% of the Green Belt.

2.5.15 In addition, as stated in the Vision Document, the development of the Site would provide 160ha of public open space, with a large amount within the Green Belt itself. This includes the provision of greenway corridors to the east of the Site. The landscaping mitigates the impact of the development, thereby not undermining the purposes of the remaining Green Belt and contributing positively the overall landscape in accordance with Paragraph 159 of the 2024 NPPF.

2.5.16 As the Site represents just 0.5% of the Green Belt in Greater Cambridge, and only 0.4% if the Sustainable Travel Hub is removed, and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.

b) There is a demonstrable unmet need for the type of development proposed 2.5.17 As stated above, our client considers that the is a demonstrable need for additional, sustainable new settlements with locational benefits adjacent to approved strategic transport infrastructure.

2.5.18 Therefore, it is considered that these representations have demonstrated that there is a demonstrable unmet need for additional housing to support the Local Plan.
c) The development would be in a sustainable location, with particular reference to paragraphs 110 and 115 of this Framework

2.5.19 As previously stated, the Site incorporates the Scotland Farm Sustainable Transport Hub. The Vision Document also shows how Scotland Park has been designed to be a walkable settlement, comprising linked villages focused on the central Town Centre Hub. The Town Centre hub includes community facilities, such as schools, retail, leisure and health uses.

2.5.20 Therefore, the Site is in accordance with Paragraph 119 of the 2024 NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel and can be accessed by sustainable transport modes.

d) Where applicable, the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

2.5.21 The Site's response to the 'Golden Rules' is set out below:
a) Affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework or (ii) until such policies are in place, the policy set out in paragraph 157 below.

2.5.22 Paragraph 157 seeks a 50% affordable housing provision prior to the adoption of the new Local Plan. As the Site seeks to be an allocation in the emerging Local Plan, it should be considered against part (i).

2.5.23 Emerging Policy H/AH: Affordable Housing states that major sites should be seeking 40% affordable housing. Table 6 of the emerging Local Plan provides the affordable housing tenures for 15 or more dwellings.

2.5.24 Our client is committed to the provision of affordable housing as part of the overall housing delivery on the Site.
b) Necessary improvements to local or national infrastructure

2.5.25 Scotland Park already benefits from high-quality existing infrastructure or infrastructure that has been committed (e.g. its adjacency to the A428 junction, the availability of power supply and drainage, and the future provision of the Scotland Farm Sustainable Transport Hub).

2.5.26 Despite the above, the Vision Document states that the new settlement will provide land for new local infrastructure. Our client would be willing to discuss the requirements in greater detail with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.5.27 It is clear that the development will generate a need for contributions as well as the provision of the land in respect of (inter alia) healthcare, education, employment and skills and transport. Our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations but, as stated, above, is willing to provide the land to support these necessary facilities, such as the schools.

2.5.28 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).

c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.5.29 The Vision Document highlights the importance as providing open space not just to support new residents but residents in nearby settlements.

2.5.30 The Vision Document states that the new settlement is a landscape-led development, creating up to 160 hectares of newly publicly accessible green spaces. The Vision Document also sets out a network of greenway corridors, providing attractive and safe pedestrian routes through the development. The Vision Document further notes that other public open spaces includes sport pitches, community allotments and a community orchard. Therefore, it is clear that the proposed new settlement accords with part c) of the NPPF paragraph 156.

2.5.31 In conclusion, our client considers that significant parts of the Site meet the definition of Grey Belt as set out in national policy and that the Council's strategic parcel-based assessment does not adequately reflect either the approved Scotland Farm Sustainable Transport Hub or the Site's wider role in supporting sustainable growth. The Site benefits from a unique combination of committed strategic transport infrastructure, the ability to deliver a substantial amount of housing, extensive green infrastructure and supporting community facilities. As such, Scotland Park represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge. Its allocation would not only make a significant contribution towards meeting housing needs, but would also improve the resilience, flexibility and effectiveness of the emerging Local Plan by providing an additional growth location capable of delivering homes alongside infrastructure at an early stage in the Plan period. Accordingly, Scotland Park should be identified as a proposed allocation within the emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF. In particular, the Plan has failed to adequately consider Scotland Park as a reasonable alternative growth option and places significant reliance on ambitious delivery assumptions associated with a small number of strategic allocations.

3.1.2 The Plan relies on new settlements, which are dependent on large pieces of infrastructure being delivered, such as CSET, which have not yet been approved. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. Therefore, the housing trajectory is subject to material delivery risk. In contrast, Scotland Park benefits from the approved C2C scheme and associated Scotland Farm Sustainable Transport Hub, providing a significantly greater degree of certainty regarding the delivery of strategic transport infrastructure and supporting a more resilient approach to housing delivery. Scotland Farm benefits from high quality existing infrastructure, such as its proximity to the A428 junction and power, meaning it can be delivered more quickly.

3.1.3 Our client also has concerns over the deliverability of the new settlements to provide more than 200 dwellings per annum, which is considered a more realistic delivery assumption than set out in the latest Lichfield's start to finish report. Consequently, there is a realistic prospect that housing delivery could fall below the levels assumed within the Council's trajectory.

3.1.4 Therefore, the emerging Local Plan should identify additional sustainable growth opportunities capable of strengthening the resilience and flexibility of the development strategy and providing greater confidence that housing needs can be met throughout the Plan period.

3.1.5 The evidence behind the emerging Local Plan notes that there is a need for additional Mid Tech space, and the focus for logistics is on the A14 corridor. Whilst Eddington will make an important contribution, it remains unclear whether the proposed employment allocations will fully address the identified requirement for Mid Tech floorspace. The Site is ideally located as it is adjacent to the Strategic Road Network and can take advantage of the Scotland Farm Sustainable Transport Hub. Its location means that it can take advantage of the government's emphasis on the Oxford to Cambridge Corridor.

3.1.6 Scotland Park therefore represents a logical location to accommodate additional employment growth, including warehousing and logistics, alongside the delivery of housing and supporting infrastructure. There is already an existing B8 use onsite, which can act as a catalyst for more commercial growth, which can open up the Site more sustainably.

3.1.7 Our client maintains that the updated Green Belt evidence base does not adequately reflect the site-specific circumstances at Scotland Park, as it considers large Green Belt parcels, rather than assessing the Site on its own merits. In particular, insufficient regard has been had to the approved Scotland Farm Sustainable Transport Hub and the changed planning context arising from the approved C2C scheme. The Site clearly falls within the definition of Grey Belt.

3.1.8 The proposed new settlement, Scotland Park, provides a suitable additional allocation. As it is a new settlement, it will incorporate a range of services and facilities, within walking distance, including primary and secondary schools as well as the Scotland Farm Sustainable Transport Hub. The Site benefits from a unique combination of committed transport infrastructure, substantial housing capacity, employment opportunities, community infrastructure and extensive public open space. As such, it represents one of the most sustainable and deliverable strategic growth opportunities available to Greater Cambridge and would materially strengthen the justification, effectiveness and overall resilience of the emerging Local Plan.

3.1.9 Accordingly, our client requests that the Local Plan is modified to allocate Scotland Park as a strategic mixed-use new settlement, comprising approximately 10,000 homes, employment land, supporting infrastructure, community facilities and extensive public open space, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map. Such an allocation would provide additional flexibility within the development strategy and improve confidence that Greater Cambridge's housing and employment needs can be met throughout the Plan period.

3.1.10 Our client wishes to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.


Footnotes:
1 cambourne-to-cambridge-decision-letter.pdf
2 Housing Delivery Study Addendum 2026-06-30
3 Cambridge Housing Delivery Study Addendum October 2025
4 start-to-finish-3 how-quickly-do-large-scale-housing-sites-deliver.pdf
5 EBGCLPIWSSMar25v1Mar25 0.pdf
6 A428 Black Cat to Caxton Gibbet improvements - National Highways
7 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf
8 Greater Cambridge Green Belt Assessment
9 Greater Cambridge Green Belt Assessment
10 https://www.gov.uk/government/statistics/localauthority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

[Please refer to the submission attachments for the appendices.]