Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Policy S/JH: New jobs and homes
Representation ID: 214297
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
The draft Local Plan overly relies on Neighbourhood Plans to provide 1,543 homes across 27 areas. Thakeham argues this approach is unsound, as many Neighbourhood Plans are recently adopted without allocating sites, they are slow to update, and face reduced support following the withdrawal of government funding. The strategy also relies heavily on large-scale developments and new settlements, with limited rural growth, risking the decline of rural services and housing supply delays. Thakeham recommends allocating more smaller rural sites and using the Government-preferred Sedgefield method to
demonstrate a more robust five-year housing land supply.
Object
Greater Cambridge Local Plan: Proposed Submission
Appendices
Representation ID: 214483
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Appendix D
Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.
With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/DS: Development strategy
Representation ID: 214485
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.
As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/SH: Settlement hierarchy
Representation ID: 214487
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Thakeham supports the inclusion of a settlement hierarchy within the emerging Local Plan, that reflects the size and sustainability of the settlements within the District. Whilst a settlement hierarchy is included within the draft Local Plan, the policy seeks to limit the size of new development at ‘minor rural centres’ and lower tiers.
Whilst new development should reflect the size and scale of existing developments, the policy should not restrict the scale of growth for rural settlements, as this may affect the settlement's ability to maintain its existing facilities and support necessary growth.
For existing facilities to remain viable, and for additional services and facilities to be delivered to meet new and growing needs of a settlement, there needs to be strategic growth; which the current drafting of the policy does not support.
As seen across the county, where settlements have not been able to grow, they have lost facilities such as primary schools or local shops, as there has not been the need within the settlement to keep the facilities viable and therefore, operational.
The Council should therefore consider the delivery of services and facilities alongside the planned strategic growth of settlements to ensure new facilities remain viable and work with Parish Council’s and the local community to ensure these facilities are appropriately located, meet the needs and demands of a locality, as well as emphasising that new development is required to be able to deliver these improvements.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/DE: Defined development extents
Representation ID: 214488
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Whilst the emerging Local Plan will be assessed against the 2024 National Planning Policy Framework (NPPF), draft Policy S/DE should seek to accord with Policy S5 of the 2026 NPPF. This would ensure that the Local Plan, upon adoption would not conflict with National Policy, but also widen the scope of where the principle of development would be applied allowed outside of settlements. This would subsequently allow housing to come forward where the Local Plan fails to ensure a five-year housing land supply is maintained but also allow for the continued delivery of housing to deliver above the minimum housing requirement.
Object
Greater Cambridge Local Plan: Proposed Submission
Chapter 2: Development strategy
Representation ID: 214492
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
This representation relates to a site submission (HELAA ref [208917, 208915 and 208916]: [Land between Shepreth, Orwell, Wimpole, Meldreth and Kneesworth (Wetherbrook combined), Land north east of Kneesworth and west of Meldreth, Old North Road (Wetherbrook West) and Land between Shepreth, Orwell and Wimpole (Wetherbook East)])
Thakeham are in a strong position to deliver Wetherbrook quickly as we already control the majority of land through long-term option agreements, with the remaining parcels owned by the County Council.
We anticipate being able to deliver at scale early in the build programme due in part to our vision for multiple villages surrounding a core town centre. By masterplanning the settlement in this way, we would be able to commence work across two or three villages at the same time, delivering circa 250 - 300 dwellings per annum, as well as delivering higher density development within the town area at circa 500 dwellings per annum. Therefore, with the right economic situation we could expect maximum outputs exceeding a thousand homes a year within the next 5-10 years and consistent delivery for the next two decades.
In light of the above, we believe Wetherbrook can come forward quickly once the Taskforce has identified the appropriate mechanism for delivery of these new towns.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/GB: The Cambridge Green Belt
Representation ID: 214493
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Thakeham supports and endorses to the Government’s desire to see land which does not contribute fully to the purposes of Green Belt, make a meaningful contribution to housing supply. In a letter to The Planning Inspectorate (PINS) dated 9 October 2025, Matthew Pennycook MP, the Minister of State for Housing and Planning, emphasised the important of Green Belt reviews in the plan making process, increasing the powers of PINS to enable recommendation of Green Belt reviews during Local Plan examination to identify additional sites where necessary.
The NPPF sets out within paragraph 146 that land outside of the Green Belt should be utilised to meet a Councils LHN. Where it is not possible to achieve this, Council should first seek to release previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations.
Whilst the Policy S/GB aligns with National Policy, the Council should ensure that consideration is given to promoted sites within the Green Belt that can come forward to meet the Local Housing Need, whilst not strongly contributing to purposes a), b) or d) of the Green Belt.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy CC/NZ: Net zero carbon new buildings
Representation ID: 214501
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Whilst the Local Plan is being assessed under the 2024 NPPF, the Local Plan should take the 2026 NPPF into consideration. Policy PM13 of the 2026 NPPF states that polices should not cover matters that are already addressed by Building Regulations, other than in relation to “energy efficiency, for which any standards that go beyond the current or proposed Building Regulations should have a clear and robustly costed rationale which shows that there will not be an adverse impact on the viability and deliverability of development.”
When reviewing the published viability assessment (Greater Cambridge Local Plan Viability – July 2026), the assessment fails to demonstrate a clear and robust costed rationale which shows that there will not be an adverse impact on the viability and deliverability of development. Whilst it recognises on page 121 that “meeting Net Zero carbon on new buildings will have a direct cost impact” it works on the assumption that the reduced energy use would enable the build cost increase to be reflected in sales values.
From Thakeham’s experience the delivery of net zero carbon homes does not result in increased sales value as there is not the market demand for that product. Therefore increasing cost of homes and leaving them unsold.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy CC/WE: Water efficiency in new developments
Representation ID: 214509
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Thakeham recognises that Greater Cambridge is officially designated as an area of serious water stress, and therefore water efficiency is required. However, the proposed 80 litres/person/day (for development over 100 dwellings) and 90 litres/person/day (for development under 100 dwellings) is significantly lower than the standard Building Regulation requirement of 125 litres per person per day, and the optional 110 litres per person per day which looks to be used in water scarce areas.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy BG/UGF: Urban greening factor
Representation ID: 214510
Received: 25/09/2026
Respondent: Thakeham Homes Ltd
Legally compliant? No
Sound? No
Thakeham supports that Policy BG/UGF seeks to ensure that proposals conserve and enhance any existing tree, woodland, hedge or hedgerow of value that would be affected by the proposed development both within and immediately adjacent to a site.
Whilst supportive of protecting and enhancing trees and hedgerows within developments, Thakeham would raise concern with the policy requirement for major new development to meet an ‘Urban Greening Factor’ (UGF). UGF have historically been used in urban areas such as City of London, Portsmouth City, and Southampton City. It is therefore not an appropriate measure that should be applied to rural areas as currently proposed within Policy BG/UGF.