Greater Cambridge Local Plan: Proposed Submission

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Linton to implement this approach.

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted Land North of Cambridge Road site in Linton (HELAA reference 115928) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Linton is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land North of Cambridge Road, Linton provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 230 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Linton.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton for residential development. This was given the site reference 115928 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages is likely to result predominantly in smaller, incremental development which may be less capable of delivering affordable housing and strategic infrastructure.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land North of Cambridge Road site in Linton (HELAA reference 115928), whereby they are seeking an allocation. The site is located adjacent to Linton Village College.

Policy S/JH of the draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,195 dwellings.

The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire). In summary, the housing target is not consistent with national policy because upward adjustments for growth and affordable housing have not been considered. Furthermore, it is important to note that for 5-Year Housing Land Supply purposes, the 2025 Housing Delivery Test results published in August 2026 now require Cambridge City to apply a 20% buffer to its annual housing requirement figure of 1,085 dwellings. This results in a new annual housing requirement figure of 1,302 dwellings.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Linton be provided.

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

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

Proposed Amendments

Bloor considers that Policy S/JH should be amended so that:
- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land North of Cambridge Road, Linton, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Linton would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

The Plan should therefore be amended to increase the contribution expected from sustainable Minor Rural Centres and to allocate Land North of Cambridge Road, Linton, as part of that revised strategy.

In November 2025, Bloor Homes Eastern submitted an outline planning application (25/04541) in respect of its Land North of Cambridge Road site in Linton for the erection of up to 230 dwellings including affordable housing and self / custom build plots along with a new site for a Doctor's Surgery, Open Space, allotments and associated infrastructure with all matters reserved except access

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Linton (HELAA reference 115928).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Linton does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton.

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

In Linton's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Linton contains a good range of services and facilities, and employment opportunities, including primary and secondary schools, pre-school/ nursery facilities, a leisure centre, library, food stores, public houses, shops, post office, doctor's surgery, and playing fields. It is on bus routes (13 Service) to Cambridge and Haverhill which provides a service every 30 minutes (20 minutes during Peak times). It is well-related to significant employment sites at Granta Park, the Babraham Research Campus and Addenbrookes Hospital / Biomedical Campus. The Application Site would be well- related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership's Linton Greenway project, providing a greenway/cycle route through Linton to Granta Park and Babraham Research Campus. There are also plans for a new travel hub and guided busway (CSET) off the A11 at Fourwentways and this would provide a direct connection to the Biomedical Campus and Cambridge.

The Council's Settlement Hierarchy Study Update 2025 acknowledges in paragraph 3.19 that Linton is one of the best Minor Rural Centres:

"Linton continues to be one of the highest scoring Minor Rural Centres. It has a bus service that connects it to Cambridge and Haverhill. The delivery of the Linton Greenway is underway with sections 1 and 2 now completed and it is expected that work will begin on the remaining sections in Winter 2025. The village has a variety of services including a village college. It offers a good range of shops and services which serve the rural hinterland. The village now scores two points for jobs due to an increase to job to population ratio. Despite Linton scoring highly in the assessment due to serving as a service centre, it is not considered to be comparable with settlements in the Rural Centre grouping of the hierarchy as it has a lower number of services and facilities. Therefore, it is proposed Linton will remain as a Minor Rural Centre".

However, there has been no review of the capacity of settlements to accommodate additional development for draft GCLP, or whether the development threshold limits remain relevant if no sites are available. There appears to be no major residential development opportunities within the development framework boundary of Linton, indeed Policy S/PA/LN: South of the A1307 at Linton in the Draft Plan states that within the area defined on the Policies Map, windfall residential development will not be permitted other than improvements to existing properties.

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

We note that paragraph 4.42 of the Sustainability Appraisal [SA] (July 2026) acknowledges the opportunities for development in and near to Linton:

"All four options also include development within the 'Southern cluster', which will help to ensure housing is well-located in relation to existing centres of employment. The Southern cluster villages have some services and facilities, including schools and doctors' surgeries, particularly in Great Shelford, Sawston and Linton, although it is uncertain how much capacity these have to accommodate growth. However, the scale of development in the Southern cluster should be sufficient to also provide some new services and facilities. Effects of development in this area are uncertain, as it depends on the final location of development that might be allocated".

Paragraph 4.49 goes on to highlight the benefits of development within the 'Southern cluster' villages:

" Development at these villages may help to boost the vitality and viability of village services and facilities, which is particularly likely to benefit older people and the less mobile, although growth may also put pressure on the capacity of existing services. It is not known if the demographics of the Southern cluster area differ substantially from other areas within Greater Cambridge. Effects of development in this area are uncertain, as it depends on the final location of development that might be allocated".

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land North of Cambridge Road, Linton provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

A Neighbourhood Plan Area was designated for Linton and Hildersham back in May 2014. A Pre- Submission (Regulation 14) that contained no proposed residential allocations was consulted upon between June - August 2023, but has not progressed any further.

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

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land North of Cambridge Road, Linton (Site Ref. 51654)

Object

Bloor Homes Eastern objects to the omission of Land North of Cambridge Road, Linton (HELAA reference 115928) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton (HELAA Site Ref. 115928). There are no significant constraints to development at this site. In November 2025 it submitted an outline planning application (25/04541) for the erection of up to 230 dwellings including affordable housing and self / custom build plots along with a new site for a Doctor's Surgery, Open Space, allotments and associated infrastructure with all matters reserved except access.

Development of the Site would not have a detrimental impact on any designated or non-designated heritage assets.

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

Linton contains a good range of services and facilities, and employment opportunities, including primary and secondary schools, pre-school/ nursery facilities, a leisure centre, library, food stores, public houses, shops, post office, doctor's surgery, and playing fields. It is on bus routes (13 Service) to Cambridge and Haverhill which provides a service every 30 minutes (20 minutes during Peak times). It is well-related to significant employment sites at Granta Park, the Babraham Research Campus and Addenbrookes Hospital / Biomedical Campus. The Application Site would be well- related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership's Linton Greenway project, providing a greenway/cycle route through Linton to Granta Park and Babraham Research Campus. There are also plans for a new travel hub and guided busway (CSET) off the A11 at Fourwentways and this would provide a direct connection to the Biomedical Campus and Cambridge.

The design and layout of the promoted informed by the site context and a clear understanding of the key site characteristics. These considerations have included part of the site's designation within the conservation area, the location of listed buildings off-site, on-site archaeology, the presence of overhead powerline and pylons to the west, neighbouring uses and existing highway access points and Public Right of Ways.

It is proposed that up to 230 residential dwellings would be delivered on the site. 40% (up to 88) would be affordable with 70% of these to be affordable rent and 30% intermediate tenure/ Shared Ownership. A number of self/custom-build plots would also be delivered at the site. The delivery of 40% affordable housing is complaint with Local Plan Policy, and this would be specified in the S106 Agreement.

The Proposed Development provides 10.24 Ha of land for on-site open space, comprising formal and informal open space areas within and on the edge of residential areas and a linear park through the centre of the Site, and including attenuation areas. Furthermore, provision for sport and recreational open space off-site will be provided as a financial contribution, secured by s106. A significant amount of open space will be delivered on site and this exceeds the minimum requirement to be delivered which is outlined within the open space standards provided in the adopted Local Plan.

The Proposed Development would include dedicated formal play areas, areas for informal and formal play opportunities, and areas with fitness equipment. The play strategy is based on a playable landscape to encourage active play and social interaction. The areas of open space would be easily accessible to residents of the Proposed Development and from the surrounding area. The open space and green infrastructure including landscaped areas has been provided at the edge of the Proposed Development to provide an attractive edge to the residential areas and create an attractive relationship with neighbouring areas. It is also proposed that allotments and a community orchard would be delivered within the site and these will further add to the open space offering at the site for both existing and proposed residents.

A Biodiversity Net Gain Assessment including a Biodiversity Metric Calculation Tool has been submitted with the pending Planning Application. The Proposed Development would retain the majority of existing habitats and hedgerows whilst also proposing the introduction of a comprehensive new landscaping scheme.

It is predicted in the Assessment (which has been based on the supporting Framework Plan) that the Proposed Development would provide a biodiversity net gain of 44.58% Habitat Units, and 20.21% Hedgerow Units. Therefore, the Proposed Development will result in a biodiversity net gain well in excess of the mandatory 10% requirement.

The residential development area is 6.0 Ha. Details of the proposed land uses are set out in the accompanying Parameter Plan, which also includes a red line boundary for the Site.

The Site represents a suitable opportunity to provide additional housing at a sustainable Minor Rural Centre and would contribute to the diversification and resilience of the Plan's housing supply.

The site can provide a substantial package of benefits, including:
- up to 230 new homes;
- affordable housing; self/custom-build housing;
- a site for a doctor's surgery allotments new areas of public open space;
- green infrastructure and native planting;
- sustainable drainage and biodiversity enhancements;
- pedestrian and cycle connections; and
- improved connections between the development and existing routes and facilities within Linton.

The site would therefore make a meaningful contribution to meeting the Plan's housing requirement while also supporting the vitality of Linton.

The allocation would additionally improve the resilience of the Plan's housing trajectory by providing a medium-sized site capable of contributing to housing delivery independently of the major infrastructure dependencies associated with the largest strategic allocations

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land North of Cambridge Road, Linton (HELAA Site Ref. 115928) are as follows:

1. Land North of Cambridge Road, Linton (HELAA Site Ref. 115928) be allocated in the Local Plan with the following requirements:
- Residential Site Area: 6 hectares
- Indicative capacity: up to approximately 230 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build plots as well as a Doctor's Surgery, Open Space, Allotments and associated infrastructure.

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Linton to implement this approach.

Linton is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including primary and secondary schools, pre- school/ nursery facilities, a leisure centre, library, food stores, public houses, shops, post office, doctor's surgery and playing fields. It is on bus routes (13 Service) to Cambridge and Haverhill which provides a service every 30 minutes (20 minutes during Peak times).

Linton is well-related to significant employment sites at Granta Park, the Babraham Research Campus and Addenbrookes Hospital / Biomedical Campus. The Application Site would be well- related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership's Linton Greenway project, providing a greenway/cycle route through Linton to Granta Park and Babraham Research Campus. There are also plans for a new travel hub and guided busway (CSET) off the A11 at Fourwentways and this would provide a direct connection to the Biomedical Campus and Cambridge.

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

Appendix D - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix D of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton.

The housing requirement for Linton and Hildersham in Appendix D is 96 dwellings between 2024 and 2045. It is positive that a housing requirement is identified for Linton and Hildersham, but it is considered that additional policy support is required in draft GCLP to ensure that the additional housing is actually delivered in Linton and Hildersham during the plan period. It is suggested that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Linton and Hildersham Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Linton and Hildersham Neighbourhood Plan will be made in order to address the housing requirement identified in Appendix D for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Linton and Hildersham is delivered during the plan period if the Linton and Hildersham Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Linton. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Linton through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton.

Appendix D explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages.

It is requested that the housing requirement for Linton seeks to also meet affordable housing needs. The promoted development at Land North of Cambridge Road would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Linton includes market housing, affordable housing and self-build / custom build housing to meet local needs.

Proposed Amendments The proposed changes to Policy S/RRA: Additional Allocation - Land North of Cambridge Road site in Linton. (HELAA Site Ref. 115928) are as follows:
1. A new policy be included within the draft GCLP to deal with the potential scenario where a neighbourhood plan is not updated or does not allocate land to meet the identified housing requirement identified in Appendix D. This requested change would ensure that the identified housing requirement for villages are met during the plan period.

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

The proposed changes to Policy S/RRA: Additional Allocation - Land North of Cambridge Road site in Linton. (HELAA Site Ref. 115928) are as follows:

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

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

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted Land North of Cambridge Road site in Linton (HELAA reference 115928) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Linton is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land North of Cambridge Road, Linton provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 230 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Linton.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton for residential development. This was given the site reference 115928 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages is likely to result predominantly in smaller, incremental development which may be less capable of delivering affordable housing and strategic infrastructure.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land North of Cambridge Road site in Linton (HELAA reference 115928), whereby they are seeking an allocation. The site is located adjacent to Linton Village College.

Policy S/JH of the draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,195 dwellings.

The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire). In summary, the housing target is not consistent with national policy because upward adjustments for growth and affordable housing have not been considered. Furthermore, it is important to note that for 5-Year Housing Land Supply purposes, the 2025 Housing Delivery Test results published in August 2026 now require Cambridge City to apply a 20% buffer to its annual housing requirement figure of 1,085 dwellings. This results in a new annual housing requirement figure of 1,302 dwellings.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Linton be provided.

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

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

Proposed Amendments

Bloor considers that Policy S/JH should be amended so that:
- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land North of Cambridge Road, Linton, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Linton would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

The Plan should therefore be amended to increase the contribution expected from sustainable Minor Rural Centres and to allocate Land North of Cambridge Road, Linton, as part of that revised strategy.

In November 2025, Bloor Homes Eastern submitted an outline planning application (25/04541) in respect of its Land North of Cambridge Road site in Linton for the erection of up to 230 dwellings including affordable housing and self / custom build plots along with a new site for a Doctor's Surgery, Open Space, allotments and associated infrastructure with all matters reserved except access

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Linton (HELAA reference 115928).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Linton does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton.

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

In Linton's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Linton contains a good range of services and facilities, and employment opportunities, including primary and secondary schools, pre-school/ nursery facilities, a leisure centre, library, food stores, public houses, shops, post office, doctor's surgery, and playing fields. It is on bus routes (13 Service) to Cambridge and Haverhill which provides a service every 30 minutes (20 minutes during Peak times). It is well-related to significant employment sites at Granta Park, the Babraham Research Campus and Addenbrookes Hospital / Biomedical Campus. The Application Site would be well- related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership's Linton Greenway project, providing a greenway/cycle route through Linton to Granta Park and Babraham Research Campus. There are also plans for a new travel hub and guided busway (CSET) off the A11 at Fourwentways and this would provide a direct connection to the Biomedical Campus and Cambridge.

The Council's Settlement Hierarchy Study Update 2025 acknowledges in paragraph 3.19 that Linton is one of the best Minor Rural Centres:

"Linton continues to be one of the highest scoring Minor Rural Centres. It has a bus service that connects it to Cambridge and Haverhill. The delivery of the Linton Greenway is underway with sections 1 and 2 now completed and it is expected that work will begin on the remaining sections in Winter 2025. The village has a variety of services including a village college. It offers a good range of shops and services which serve the rural hinterland. The village now scores two points for jobs due to an increase to job to population ratio. Despite Linton scoring highly in the assessment due to serving as a service centre, it is not considered to be comparable with settlements in the Rural Centre grouping of the hierarchy as it has a lower number of services and facilities. Therefore, it is proposed Linton will remain as a Minor Rural Centre".

However, there has been no review of the capacity of settlements to accommodate additional development for draft GCLP, or whether the development threshold limits remain relevant if no sites are available. There appears to be no major residential development opportunities within the development framework boundary of Linton, indeed Policy S/PA/LN: South of the A1307 at Linton in the Draft Plan states that within the area defined on the Policies Map, windfall residential development will not be permitted other than improvements to existing properties.

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

We note that paragraph 4.42 of the Sustainability Appraisal [SA] (July 2026) acknowledges the opportunities for development in and near to Linton:

"All four options also include development within the 'Southern cluster', which will help to ensure housing is well-located in relation to existing centres of employment. The Southern cluster villages have some services and facilities, including schools and doctors' surgeries, particularly in Great Shelford, Sawston and Linton, although it is uncertain how much capacity these have to accommodate growth. However, the scale of development in the Southern cluster should be sufficient to also provide some new services and facilities. Effects of development in this area are uncertain, as it depends on the final location of development that might be allocated".

Paragraph 4.49 goes on to highlight the benefits of development within the 'Southern cluster' villages:

" Development at these villages may help to boost the vitality and viability of village services and facilities, which is particularly likely to benefit older people and the less mobile, although growth may also put pressure on the capacity of existing services. It is not known if the demographics of the Southern cluster area differ substantially from other areas within Greater Cambridge. Effects of development in this area are uncertain, as it depends on the final location of development that might be allocated".

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land North of Cambridge Road, Linton provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

A Neighbourhood Plan Area was designated for Linton and Hildersham back in May 2014. A Pre- Submission (Regulation 14) that contained no proposed residential allocations was consulted upon between June - August 2023, but has not progressed any further.

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

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land North of Cambridge Road, Linton (Site Ref. 51654)

Object

Bloor Homes Eastern objects to the omission of Land North of Cambridge Road, Linton (HELAA reference 115928) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton (HELAA Site Ref. 115928). There are no significant constraints to development at this site. In November 2025 it submitted an outline planning application (25/04541) for the erection of up to 230 dwellings including affordable housing and self / custom build plots along with a new site for a Doctor's Surgery, Open Space, allotments and associated infrastructure with all matters reserved except access.

Development of the Site would not have a detrimental impact on any designated or non-designated heritage assets.

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

Linton contains a good range of services and facilities, and employment opportunities, including primary and secondary schools, pre-school/ nursery facilities, a leisure centre, library, food stores, public houses, shops, post office, doctor's surgery, and playing fields. It is on bus routes (13 Service) to Cambridge and Haverhill which provides a service every 30 minutes (20 minutes during Peak times). It is well-related to significant employment sites at Granta Park, the Babraham Research Campus and Addenbrookes Hospital / Biomedical Campus. The Application Site would be well- related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership's Linton Greenway project, providing a greenway/cycle route through Linton to Granta Park and Babraham Research Campus. There are also plans for a new travel hub and guided busway (CSET) off the A11 at Fourwentways and this would provide a direct connection to the Biomedical Campus and Cambridge.

The design and layout of the promoted informed by the site context and a clear understanding of the key site characteristics. These considerations have included part of the site's designation within the conservation area, the location of listed buildings off-site, on-site archaeology, the presence of overhead powerline and pylons to the west, neighbouring uses and existing highway access points and Public Right of Ways.

It is proposed that up to 230 residential dwellings would be delivered on the site. 40% (up to 88) would be affordable with 70% of these to be affordable rent and 30% intermediate tenure/ Shared Ownership. A number of self/custom-build plots would also be delivered at the site. The delivery of 40% affordable housing is complaint with Local Plan Policy, and this would be specified in the S106 Agreement.

The Proposed Development provides 10.24 Ha of land for on-site open space, comprising formal and informal open space areas within and on the edge of residential areas and a linear park through the centre of the Site, and including attenuation areas. Furthermore, provision for sport and recreational open space off-site will be provided as a financial contribution, secured by s106. A significant amount of open space will be delivered on site and this exceeds the minimum requirement to be delivered which is outlined within the open space standards provided in the adopted Local Plan.

The Proposed Development would include dedicated formal play areas, areas for informal and formal play opportunities, and areas with fitness equipment. The play strategy is based on a playable landscape to encourage active play and social interaction. The areas of open space would be easily accessible to residents of the Proposed Development and from the surrounding area. The open space and green infrastructure including landscaped areas has been provided at the edge of the Proposed Development to provide an attractive edge to the residential areas and create an attractive relationship with neighbouring areas. It is also proposed that allotments and a community orchard would be delivered within the site and these will further add to the open space offering at the site for both existing and proposed residents.

A Biodiversity Net Gain Assessment including a Biodiversity Metric Calculation Tool has been submitted with the pending Planning Application. The Proposed Development would retain the majority of existing habitats and hedgerows whilst also proposing the introduction of a comprehensive new landscaping scheme.

It is predicted in the Assessment (which has been based on the supporting Framework Plan) that the Proposed Development would provide a biodiversity net gain of 44.58% Habitat Units, and 20.21% Hedgerow Units. Therefore, the Proposed Development will result in a biodiversity net gain well in excess of the mandatory 10% requirement.

The residential development area is 6.0 Ha. Details of the proposed land uses are set out in the accompanying Parameter Plan, which also includes a red line boundary for the Site.

The Site represents a suitable opportunity to provide additional housing at a sustainable Minor Rural Centre and would contribute to the diversification and resilience of the Plan's housing supply.

The site can provide a substantial package of benefits, including:
- up to 230 new homes;
- affordable housing; self/custom-build housing;
- a site for a doctor's surgery allotments new areas of public open space;
- green infrastructure and native planting;
- sustainable drainage and biodiversity enhancements;
- pedestrian and cycle connections; and
- improved connections between the development and existing routes and facilities within Linton.

The site would therefore make a meaningful contribution to meeting the Plan's housing requirement while also supporting the vitality of Linton.

The allocation would additionally improve the resilience of the Plan's housing trajectory by providing a medium-sized site capable of contributing to housing delivery independently of the major infrastructure dependencies associated with the largest strategic allocations

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land North of Cambridge Road, Linton (HELAA Site Ref. 115928) are as follows:

1. Land North of Cambridge Road, Linton (HELAA Site Ref. 115928) be allocated in the Local Plan with the following requirements:
- Residential Site Area: 6 hectares
- Indicative capacity: up to approximately 230 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build plots as well as a Doctor's Surgery, Open Space, Allotments and associated infrastructure.

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Linton to implement this approach.

Linton is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including primary and secondary schools, pre- school/ nursery facilities, a leisure centre, library, food stores, public houses, shops, post office, doctor's surgery and playing fields. It is on bus routes (13 Service) to Cambridge and Haverhill which provides a service every 30 minutes (20 minutes during Peak times).

Linton is well-related to significant employment sites at Granta Park, the Babraham Research Campus and Addenbrookes Hospital / Biomedical Campus. The Application Site would be well- related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership's Linton Greenway project, providing a greenway/cycle route through Linton to Granta Park and Babraham Research Campus. There are also plans for a new travel hub and guided busway (CSET) off the A11 at Fourwentways and this would provide a direct connection to the Biomedical Campus and Cambridge.

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

Appendix D - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix D of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton.

The housing requirement for Linton and Hildersham in Appendix D is 96 dwellings between 2024 and 2045. It is positive that a housing requirement is identified for Linton and Hildersham, but it is considered that additional policy support is required in draft GCLP to ensure that the additional housing is actually delivered in Linton and Hildersham during the plan period. It is suggested that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Linton and Hildersham Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Linton and Hildersham Neighbourhood Plan will be made in order to address the housing requirement identified in Appendix D for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Linton and Hildersham is delivered during the plan period if the Linton and Hildersham Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Linton. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Linton through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land North of Cambridge Road site in Linton.

Appendix D explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages.

It is requested that the housing requirement for Linton seeks to also meet affordable housing needs. The promoted development at Land North of Cambridge Road would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Linton includes market housing, affordable housing and self-build / custom build housing to meet local needs.

Proposed Amendments The proposed changes to Policy S/RRA: Additional Allocation - Land North of Cambridge Road site in Linton. (HELAA Site Ref. 115928) are as follows:
1. A new policy be included within the draft GCLP to deal with the potential scenario where a neighbourhood plan is not updated or does not allocate land to meet the identified housing requirement identified in Appendix D. This requested change would ensure that the identified housing requirement for villages are met during the plan period.

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

Bloor considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

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

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1.Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:

Site area: 11.77 hectares

Indicative capacity: up to approximately 170 dwellings, including a policy-compliant proportion of affordable housing and provision for self/custom build

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

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

the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;

the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;

the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;

the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and

additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

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

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

2.Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

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

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

2.Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

INTRODUCTION

The consultation on a Reg. 19 Draft Greater Cambridge Local Plan (draft GCLP) is taking place between 3ʳᵈ August 2026 and 25ᵗʰ September 2026. This document provides draft representations to the consultation.

Due to the fact that the representations will be submitted in relation to individual policies, rather than read as a whole, there is inevitably significant repetition contained within them.

The final version of the representations will be uploaded to the online consultation system.

REPRESENTATIONS TO DRAFT GCLP

Vision for Greater Cambridge

Comment

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference: 115354) for residential development.

Bloor supports the overarching Vision for Greater Cambridge, including its objectives relating to quality of life, climate change, sustainable transport, housing provision, infrastructure, biodiversity and green infrastructure.

However, the spatial strategy and housing requirement should be amended to ensure that these objectives are capable of being delivered in practice.

In particular, the Plan places substantial reliance upon a number of large strategic developments and new settlements. The delivery of these sites is dependent in several cases upon significant infrastructure, including transport infrastructure, and the assumed delivery rates should be supported by robust evidence from comparable developments and realistic infrastructure delivery programmes.

There is consequently a need for greater flexibility in the housing supply strategy. This should include a stronger role for sustainable Minor Rural Centres where additional development can be accommodated without reliance upon the delivery of major strategic infrastructure.

Papworth Everard is identified as a Minor Rural Centre and contains a range of services, facilities, employment opportunities and public transport connections. Additional development at the settlement would therefore support the objectives of the Plan by providing housing in a location where residents can access existing services and facilities, while also supporting their continued vitality.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to contribute to this flexibility. The site is capable of providing up to 170 dwellings, including affordable housing, and would provide an additional source of housing delivery alongside the Plan's strategic allocations.

Bloor therefore considers that the Vision can only be effectively translated into a sound spatial strategy if the Plan provides greater flexibility in the location and timing of housing delivery, including through additional allocations at sustainable villages such as Papworth Everard.

Strategic Priorities

Comment

Bloor Homes Eastern has promoted its 11.77 ha Land East of Ridgeway and Old Pinewood Way, Papworth Everard site for residential development. This was given the site reference 115354 in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) 2026.

The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for the draft GCLP are unlikely to fully deliver the strategic priorities.

In particular, the current development allocation policy:
- does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs and are likely to take significantly longer time to deliver.
- does not make provision for sufficient housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

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

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

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

Policy S/JH: New Jobs and Homes

Object

These representations are submitted by Bloor Homes Eastern in its capacity as a site promoter with regards to Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354), whereby they are seeking an allocation. The site is located east of Old Pinewood Way and Woodhead Place.

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

The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,289 dwellings per annum (based upon the identified annual need for 1,085 dwellings in Cambridge and 1,204 dwellings in South Cambridgeshire).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Growth Plan states that with National Reach and Global Impact very large numbers of new jobs are anticipated to be delivered at the following two locations within Greater Cambridge:
- There is scope for significant expansion of the Cambridge Biomedical Campus. The 2024 Spatial Framework for the site sets out how this can become 1,600,000sqm by 2050, driving job creation by attracting and growing new life science business, capturing internationally mobile investment, including multinational R&D headquarters and building the world's most research activated healthcare infrastructure. The projected Growth in jobs is an additional 23,000 jobs by 2050.
- Cambridge Business Park: The Crown Estate have unveiled bold proposals to regenerate Cambridge Business Park and create a new innovation ecosystem in Northeast Cambridge. The £1.5bn project will create over 8,000 jobs

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

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

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

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

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

At the more local level, we note that the Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing (2023) produced by Iceni Projects Limited identified in paragraph 5.20 that "completions for warehousing are also positive for net and gross, particularly in South Cambridgeshire at Papworth Everard (Stirling Way)". This demonstrated the strength of the local employment market.

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

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

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

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year-below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy- compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm. If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Papworth Everard be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village-edge sites such as Land to the east of Ridgeway and Old Pinewood Way, Papworth Everard can support early housing delivery and help meet the revised requirement.

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

Proposed Amendments

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

- the relationship between the employment forecast, housing requirement, labour-force growth and commuting patterns is reassessed;
- the Council provides clear evidence demonstrating why an appropriate commuting adjustment is not required, or applies such an adjustment where the evidence supports it;
- the housing requirement is reviewed in light of economic growth ambitions and infrastructure investment;
- the implications of affordable housing need and the deliverability of affordable housing from the proposed site allocations are properly reflected; and
- additional sustainable and deliverable sites, including Land East of Ridgeway and Old Pinewood Way, Papworth Everard, are allocated to provide greater flexibility and resilience in housing delivery.

Policy S/DS: Development Strategy

Object

Bloor Homes Eastern objects to Policy S/DS because the proposed development strategy places substantial reliance upon strategic-scale developments and does not provide sufficient flexibility through additional allocations at sustainable Minor Rural Centres.

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

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

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

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

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

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

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

Additional development at Papworth Everard would therefore complement, rather than undermine, the strategic development strategy. It would diversify the Plan's housing supply, reduce reliance on a limited number of strategic sites and provide an opportunity for earlier delivery of housing and affordable housing.

Whist Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

Proposed Amendments

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

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

2. Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Bloor site at Papworth Everard (HELAA reference 115354).

Policy S/SH: Settlement Hierarchy

Object

Bloor Homes Eastern objects to Policy S/SH insofar as its application to Papworth Everard does not provide an effective means of meeting the housing and affordable housing needs of the settlement.

Policy S/SH of the draft GCLP defines the settlement hierarchy. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard.

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

In Papworth Everard's case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

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

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:

- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Indeed, Policy S/AMC/PH seeks to allocate the 5.25 ha Papworth hospital site for development. It explicitly states that "new housing development and/or redevelopment for housing will not be permitted. Conversion of existing buildings of character for residential use may exceptionally be permitted where it would be the most appropriate use of the buildings and recreate the character of the original Papworth Hospital buildings fronting the historic landscaped parkland setting of Papworth Hall".

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

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

Proposed Amendments

Bloor Homes Eastern therefore considers that Policy S/SH should be amended, or supported by an associated allocation policy, to enable appropriate edge-of-settlement growth at sustainable Minor Rural Centres where internal capacity is insufficient.

Land East of Ridgeway and Old Pinewood Way, Papworth Everard provides an appropriate opportunity to implement this approach.

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

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

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

Policy S/DE: Defined Development Extents

Object

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

No Neighbourhood Plan Area application has yet been made in relation to Papworth Everard. The currently defined development framework boundary for Papworth Everard means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village's identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services.

Furthermore, the policy relating to the proposed redevelopment of the Papworth Hospital site does not support housing provision on the site. Therefore, housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

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

Proposed Amendments

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

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

2. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard, which could make an important contribution to the housing land supply in the early years of the Plan period, prior to when many of the larger housing allocation sites will be capable of delivery.

Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354)

Object

Bloor Homes Eastern objects to the omission of Land East of Ridgeway and Old Pinewood Way, Papworth Everard (HELAA reference 115354) from the draft GCLP and seeks its allocation for residential development.

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

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

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

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

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354. There are no significant constraints to development at this site.

Papworth Everard contains a good range of services and facilities, and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Site would be well-related to The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

The Site is located on the north eastern edge of Papworth Everard and is bound by housing to the west and a woodland plantation to the south. The housing at Ridgeway to the north west, consists of semi-detached properties dating from the 1950s, and a mix of detached and semi-detached properties from the 1980s. A woodland belt lies on the western boundary of the southern half the Site. The woodland belt is approximately 20 metres deep and approximately 6-8 metres high, and contains a number of informal footways. It provides a buffer between the housing on Old Pinewood Way and the Site. The housing at Old Pinewood Way to the west, consists of large detached housing dating from the late 1990s to the early 2000s.

The Site is wholly within Flood Zone 1. In relation to climate change, it is not located within a climate- change-adjusted flood zone. With regard to surface water: 1% lies in a 1-in-1,000-year event.

To the south of the Site lies the mature woodland of Papworth Wood, and the northern and eastern boundaries of the Site are open to the countryside.

The open fields to the east stretch up to the next village of Elsworth, which is located approximately 2km east. The landscape is made up of large, open, extensively farmed, arable fields, with evidence of hedgerow removal creating sizable irregular shaped fields. Although the open fields stretch up to Elsworth the topography of the landform prevents any visual connection with the village.

The northern half of the eastern boundary is defined by a ditch with intermittent trees and shrubs. As the eastern boundary continues south, it is marked by an informal unmade footway which turns due west to make up the southern boundary to Papworth Wood.

The southern half of the western boundary is defined by a woodland plantation, which forms a buffer between the Site and the development on Old Pinewood Way. A number of informal footways occur within this woodland.

The northern half of the western boundary is overlooked by a number of properties on Ridgeway. The Site's frontage with Ridgeway is formed by a scattering of semi-mature and mature trees, but is otherwise open.

There are no listed buildings within the Site. The Papworth Everard Conservation Area contains six Listed Buildings and is located approximately 325m to the south of the Site. Papworth Hall, an associated lodge located 600 metres south of the Site is Grade Il listed. Further listed buildings can be found along Ermine Street and Church Lane, including St. Peter's Church. However, these buildings have no inter-visibility with the Site and are separated from them by the urban area of Papworth Everard.

A moated site which is a scheduled monument is located approximately 500m to the south. It is well screened from the Site by the built development and woodland. The development of the Site therefore is unlikely to have any effect upon the setting of the scheduled monument.

We note that the 2026 Housing and Employment Land Availability Assessment (HELAA) Historic Environment Comments which state that "having considered the additional information, the site assessment remains green. Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

We also note that the 2026 HELAA also contain the Archaeology Officer comments, which state that "having considered the updated site details and context, the assessment score has been changed to green. Archaeological evaluation, undertaken in 2015, identified evidence for Bronze Age and Iron Age settlement. Archaeological excavation would be necessary in advance of development, secured by condition of planning permission".

Comments from the Site Access Officer within the 2026 HELAA confirm that the proposed site is acceptable in principle subject to detailed design.

There are no Tree Preservation Orders within or adjacent to the Site.

Two Category B trees are located on the Site's western boundary, one in the northern half of the Site and the other in the southern half. The remainder of the trees and hedges along the Site boundary are of Category C and U standard.

The site provides an opportunity to create a new development in a sustainable location, within easy reach of local services and on the edge of the existing residential area.

- An opportunity exists to provide a new recreational footway running through the proposed development, providing potential links to the informal footways that run through the woodland to the west of the Site and connecting to the existing public footpath which runs through the Site.
- Create new areas of open space throughout the Site, providing a strong green infrastructure.
- New native tree and shrub planting should be incorporated within the housing areas and areas of open space to create a well-landscaped character to the development. New landscaping should also be used to reinforce existing vegetation along the Site's boundaries.
- Opportunity to design Sustainable Drainage Systems (SuDS) features to promote local ecology and biodiversity (i.e. swales / infiltration basin) and provide a distinctive character to the development

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

1. Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) be allocated in the Local Plan with the following requirements:
- Site area: 11.77 hectares
- Indicative capacity: up to approximately 170 dwellings, including a policy- compliant proportion of affordable housing and provision for self/custom build

Policy I/ST: Sustainable Transport and Connectivity

Comment

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

Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Papworth Everard to implement this approach.

Papworth Everard is defined as a Minor Rural Centre in the settlement hierarchy. It provides a good range of services and facilities and employment opportunities, including a Village Hall, The Printworks (a new social enterprise hub featuring meeting rooms, collaboration spaces, hot-desking, a café, and a microbrewery), church, primary and special needs schools, pre-school/ nursery facilities, food stores, restaurant / take-aways, shops, post office, doctor's surgery, and playing fields.

Papworth Everard possesses the following bus route services:
- 8: Hilton - Cambridge
- 67/67B: - St Ives - St Neots or Papworth Everard
- X2: Huntingdon - Cambridge Railway Station
- X3: Huntingdon - Addenbrookes Hospital

The village is well-related to significant employment hubs with various parks include Huntingdon (Stukeley Meadows, Edison Park), St Neots (Lakeside, Eaton Socon), and the major Cambridge Science/Business Parks (Girton, Milton), offering diverse opportunities in tech, logistics, and services, with many smaller industrial estates scattered between these towns and closer to Papworth itself.

The Application Site would be well-related to the The Papworth Everard Cycleway Scheme (often referred to within the context of the Greater Cambridge Greenways projects) is a completed infrastructure project that created a dedicated, 3.5-metre-wide, two-way, segregated path for cyclists, pedestrians, and equestrians, connecting the village of Papworth Everard with the nearby settlement of Cambourne.

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

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

Object

Appendix C of the draft GCLP identifies a housing requirement for the period 2024 to 2045 for those designated neighbourhood plan areas. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Given the absence of any Neighbourhood Area designation, there is no specified housing requirement for Papworth Everard contained in Appendix C of the Draft Plan in relation to the period between 2024 and 2045. It is considered that additional policy support is required in the draft GCLP to ensure that the additional housing is actually delivered in Papworth Everard during the plan period. In addition, we suggest that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

There is no made Papworth Everard Neighbourhood Plan that allocates any land for development. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Papworth Everard Neighbourhood Plan will be made in order to address the housing requirement for the village. There is no policy in the draft GCLP that would ensure the identified housing requirement for Papworth Everard is delivered during the plan period if the Papworth Everard Neighbourhood Plan is not progressed and made. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirements are met.

There is limited capacity within the defined settlement boundaries to meet the identified housing requirement for Papworth Everard. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development.

As set out elsewhere in these representations, allocations should be made in Papworth Everard through the draft GCLP to meet the identified housing requirement for the village. Bloor Homes Eastern has promoted the Land East of Ridgeway and Old Pinewood Way site in Papworth Everard.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for the draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages and that indicative housing numbers be set out in respect of villages that lack any designated Neighbourhood Area.

It is requested that the housing requirement for Papworth Everard seeks to also meet affordable housing needs. The promoted development at Land East of Ridgeway and Old Pinewood Way would include housing and affordable housing to meet local needs of the village.

The promoted development by Bloor Homes Eastern in Papworth Everard includes market housing, affordable housing to meet local needs.

Proposed Amendments

The proposed changes to Policy S/RRA: Additional Allocation - Land East of Ridgeway and Old Pinewood Way, Papworth Everard (Site Ref. 115354) are as follows:

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

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