Greater Cambridge Local Plan: Proposed Submission

The spatial strategy should allocate sustainable Green Belt sites which lies adjacent to villages, for residential development. This would bring investment in infrastructure and services to these villages, improving health services and public transport.
Land at Duxford Road, Whittlesford should be allocated for development. It lies in a highly sustainable location, between Whittlesford village, the settlement of Whittlesford Bridge and Whittlesford Parkway Railway Station.

The plan proposes the allocation of strategic sites to deliver the majority of new homes over the plan period. In addition to the current supply, an additional 9,691 new homes are required to meet the housing need over the plan period from 2024 to 2045.

These are planned to be delivered at Cambridge East (3,950 new homes), Cambridge Biomedical Campus (1,000 homes for local workers), Eddington (2,250 new homes in plan period), at new settlements including Cambourne North (2,550 new homes), Land adjacent to Grange Farm (2,550 new homes) as well as significant numbers at Wellcome Genome Campus and Babraham Research Campus.

With the exception of Land at Grange Farm, all the proposed additional sites lie within or adjacent to Cambridge City; allocations in the rural southern cluster amount to 43 homes on Babraham Campus, 60 at Maarnford Farm Duxford, two allocations for a total of 140 dwellings in Melbourn and 65 units at Caldecote.

We contend that the development strategy is not sound in three regards. Firstly, it places almost exclusive emphasis on the delivery of large, strategic sites. Figure 9 of the draft Local Plan confirms that the Greater Cambridge Plan intends that 44% of new housing over the plan period will be delivered in new settlements. This is a very high figure which makes the Plan heavily reliant on the delivery of strategic infrastructure, and reduces the flexibility and robustness of the spatial strategy to respond to changing circumstances and the validity of the housing market. The development strategy is entirely reliant on the successful delivery of these sites. If one or more were to fail, there is little flexibility in the Plan to ensure that the timely delivery of new homes continues, and no back up plan to deliver the homes through additional, smaller sites.

The Lichfields ‘Start to Finish’ study (3rd edition, March 2024) notes that:

‘Sites of 1,000+ dwellings take on average five years to obtain detailed planning permission, then a further 1.3 - 1.6 years to deliver the first dwelling’.

In contrast, Table 3.1 of the report refers to build out times from validation of a planning application for 100-499 new homes, and notes that the median timeframe is five years but the lower quartile of the range is 2.6 years. In our experience this is overly optimistic and unrealistic – particularly given the current and foreseeable pressures on the economy and the now well documented slow down in housing delivery It is important to bear in mind too that these time frames are from the validation of a planning application; from allocation in a Regulation 19 plan such as the draft Greater Cambridge Local Plan Review, they will be considerably longer, to allow for the public consultation on draft Plans, and the Examination of the Plan.

Land at Duxford Road could be built out at the quicker end of this scale. This is for several reasons;
i. Because the site is mid sized, being promoted for up to 350 new homes;
ii. Because no major infrastructure is required; and
iii. As Croudace Homes is a developer with an option on the land, build out of this site would be able to begin far more quickly than on land managed by a promoter, who would need to sell the site to a developer following a planning approval.

To address the almost exclusive focus on large, strategic sites, the policy could be made sound by the allocation of additional smaller sites for development. These sites would require significantly less infrastructure provision than the large, strategic sites, and could be brought forward in a timely manner. The addition of these sites would improve the flexibility of the spatial strategy and the robustness of the Plan and ‘plug the gap’ in any shortfalls in delivery through the strategic sites. An example of such a site is Land at Duxford Road, Whittlesford.

Secondly, the development strategy is unsound in its spatial distribution because it focuses development almost entirely within and adjacent to Cambridge City, and to the north, east and west of the city. With the exception of Grange Farm, there is very little housing proposed in South Cambridgeshire.

Figure 9 of the draft Plan confirms that the strategy provides only 15% of the new housing in rural areas, and yet rural areas comprise the majority of the area of the joint authority. The South Cambridgeshire website confirms that:

‘Over 50% of the total population of the combined Greater Cambridge area (which includes both authorities) lives in the rural villages within South Cambridgeshire.’
To compare the strategy with previous plans, 30% of new homes were provided in rural areas under the Cambridgeshire and Peterborough Structure Plan 2003, and 23% under the adopted Local Plans. Ignoring the smaller settlements and not allocating sites adjacent to them removes the ability for these settlements to grow and thrive at a scale which is suitable for them. It results in under provision of infrastructure and affordable housing (which would benefit both new and existing residents) and of investment in community facilities and it reduces choice for people looking to buy houses. It also ignores market demand and the fact that many people do not want to live in large scale, new developments, but in smaller developments which are adjacent to an established community.

Thirdly, the development strategy is unsound because it ignores the potential of sustainable, Green Belt sites to be allocated for development. Paragraph 148 of the NPPF 2024, under which this Plan is being examined, states that:

‘Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary.’

Currently the draft Plan only allocates two sites for release from the Green Belt and for economic development; Babraham Campus and Cambridge Science Park. In the context of the recent changes in national planning policy in August which identifies housing need as one of the very special circumstances which could justify release of land from the Green Belt, and the Government’s agenda for housing growth, the strategy must now be amended to release more sites from the Green Belt.

Land at Duxford Road lies within the Green Belt, in a highly sustainable location, between Whittlesford village, the settlement of Whittlesford Bridge and Whittlesford Parkway Railway Station. Whittlesford is identified in the settlement hierarchy as a Group Village, which offers a range of shops, services and facilities. Whittlesford Parkway is a well connected railway station which offers frequent (half hourly) services to London and to Cambridge. With access to the range of services in Whittlesford village and the public transport connectivity provided by the train, Land at Duxford Road, Whittlesford lies in a highly sustainable location. We contend that it should be removed from the Green Belt, and allocated for residential development.

In summary, we contend that Policy S/DS as drafted is unsound on 3 counts:

• It places too much reliance on the delivery of large, strategic sites and as such the Plan is neither flexible to respond to changing circumstances, nor robust. In isolation, this is not the best option when compared to other, reasonable choices and is not justified.
• The spatial distribution of sites focuses on the Cambridge City area and does not deliver new homes in South Cambridgeshire. It does not therefore meet housing need across the District and provides for little investment in infrastructure, affordable housing or specialist housing in South Cambridgeshire.
• It ignores the potential of sustainable Green Belt sites to deliver housing in a locations where people have active travel choices and access to shops, services and facilities.

To address these concerns, the Plan should be amended to allocate Land at Duxford Road, Whittlesford for residential development. This would improve the flexibility of the Plan, increase investment in infrastructure, affordable housing and community facilities in South Cambridgeshire and deliver homes in a sustainable location with access to an established community with a range of services, and excellent public transport provision in the form of the train service to Cambridge, London and intervening stations.

Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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

Our client requests that the Proposed Submission Local Plan be modified to allocate the Site for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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

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

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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

Need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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

a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The
requirement for smaller allocations as part of a “hybrid” approach is supported by the Addendum (paragraph 3.2.71). Given the Plan’s reliance on new settlements, the
allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the
earlier years of the Plan period.

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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

The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge’s proposed housing trajectory, particularly in the first five years following adoption.

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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

Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

1 Introduction

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

1.1.2 Our client has an interest at land off Beach Road, Cottenham, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.3 Prior to the commencement of the latest Local Plan preparation, the Site has been promoted by Croudace Homes during the previous iteration of the Greater Cambridge Local Plan.

1.1.4 These representations build on the submission made on behalf of our client to the Regulation 18 consultation, reattached for information at Appendix 2. Details of site context and Croudace Homes are set out in the Regulation 18 representations and therefore are not repeated as part of these representations for brevity. However, following submission of the previous representations, there has been additional evidence published by Greater Cambridge which affects the context of the Site; this explicitly referenced below.

1.2 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.2.1 As part of its Regulation 18 representations, our client set out justification that the Site falls within the definition of grey belt as set out in national policy and should be allocated in the emerging Local Plan. The representations noted the previous Green Belt Assessment published by the Council (August2021), which concluded that the Site does not strongly contribute to the purposes of the Green Belt. The Site forms part of Parcels CH1 and CH2, shown on the Plan below:


Figure 1.1: Green Belt Assessment - Parcel Designations
[Please refer to the submission attachments for the referenced figure.]

1.2.2 In the 2021 Green Belt Assessment, Parcel CH1 made a limited/no contribution to Cambridge Purpose 1 (preserving the unique character of Cambridge), a relatively limited contribution to Cambridge Purpose 2 (maintaining and enhancing the quality of Cambridge's setting) and a relatively limited contribution to Purpose 3 (preventing communities from merging into one another).

1.2.3 Parcel CH2 was considered to make a limited/no contribution to Cambridge Purpose 1, a moderate contribution to Cambridge Purpose 2 and a moderate contribution to Cambridge Purpose 3. Therefore, the two parcels did not strongly contribute to the purposes of the Green Belt.

1.2.4 In July 2026, the Council published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as grey belt.

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

1.2.6 The findings of the July Green Belt Assessment in relation to Parcels CH1 and CH2 are set out in the table below:

Table 1.1: Conclusions on Parcels CH1 and CH2 - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced table.]

1.2.7 The Assessment has also produced a Green and grey belt map for Cottenham, which is set out in Figure 1.2 below.

Figure 1.2: Cottenham grey belt Map - Greater Cambridge Green Belt Assessment (July 2026)
[Please refer to the submission attachments for the referenced figure.]

1.2.8 As shown in the map above the 2026 Green Belt Assessment finds that the Site falls within the definition of grey belt as set out in national policy. It is considered that the Site does not make a 'strong' contribution to the other purposes of the Green Belt as set out in Greater Cambridge's 2021 Assessment.

1.2.9 As the Site aligns with the definition of grey belt, our client has updated the Vision Document to reflect this change. It is attached to these representations at Appendix 3.

1.2.10 Our client is pleased that the updated evidence produced by Greater Cambridge indicates that the Site is grey belt. In this context, our client considers that the Site should be considered as a proposed allocation in the emerging Local Plan. This is due to concerns about the Local Plan not providing a 'deliverable' supply of homes on adoption (as set out in paragraph 72 of the 2024 National Planning Policy Framework), which is the version of the NPPF the Plan will be assessed against. Further details on our client's concerns are set out in Chapter 2 of these representations.

1.3 Regulation 19 Consultation

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

1.3.2 To be considered 'sound', it is recognised that the Local Plan must meet the criteria set out in Paragraph 36 of the 2024 National Planning Policy Framework (NPPF). Whilst a subsequent NPPF was published in August 2026, it is recognised that the intention of Greater Cambridge is to submit the emerging Local Plan to the Inspectorate in December 2026. Therefore, it will be assessed against the 2024 NPPF.

1.3.3 Notwithstanding the above, our client considers it appropriate for Greater Cambridge to start applying the policy direction of the August 2026 NPPF given that any future Local Plan will need to be considered against the latest version.

1.3.4 Paragraph 36 of the 2024 NPPF states that Local Plans should be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, SO that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified- - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground;
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

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

1.4 Structure of Document

1.4.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations and refers to Greater Cambridge's latest Green Belt Assessment and its update in relation to the Site.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.


2 Response to Consultation

2.1.1 This Chapter sets out our client's response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan. Our client considers that there are fundamental concerns over the Local Plan being able to provide 'deliverable' housing, particularly on adoption of the Local Plan. These issues are set out in further detail below.

2.2 The Need for Additional Deliverable Housing

2.2.1 Our client has compared the housing delivery forecast provided in the AECOM 2026 Addendum³ against the previous forecast provided as part of the Regulation 18 consultation in January 2026⁴.

2.2.2 The table below sets out the headline comparison between the two trajectories:

Table 2.1: Comparison between 2025 Regulation 18 Trajectory and 2026 Regulation 19 Trajectory
[Please refer to the submission attachments for the referenced table.]

2.2.3 The table below compares the five year housing land supply trajectory set out in both the January 2026 Regulation 18 evidence and the updated AECOM Addendum:

Table 2.2: Comparison between 2026 Regulation 18 and 2026 Regulation 19- Annual Trajectory
[Please refer to the submission attachments for the referenced figure.]



2.2.4 There is a clear reduction in the number of 'deliverable' dwellings on adoption of the Local Plan, which is a requirement under Paragraph 72 of the NPPF, which states:

"Planning policies should identify a supply of:
a) Specific, deliverable sites for five years following the intended date of adoption".

2.2.5 The weakening of the five-year housing land supply position, which could deteriorate yet further, means that it is imperative that more sites are brought forward on adoption of the Local Plan to strengthen this position. Smaller sites in highly sustainable rural settlements, such as Cottenham, are better placed to meet that demand, given the reduced need for infrastructure. Therefore, the Site should be allocated as a new allocation.

2.2.6 This is highlighted by Greater Cambridge acknowledging that the number of completions through new allocations has been reduced for the first five years on adoption, as detailed in Table 2.3 below:

Table 2.3: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - New Allocations
[Please refer to the submission attachments for the referenced figure.]

2.2.7 The 2026 Addendum indicates that delivery from new allocations is projected to increase substantially thereafter, as new settlements begin to make a greater contribution later in the Plan Period (principally 2038/39 and 2039/40). The Addendum therefore confirms that the Council's strategy relies on higher levels of delivery from the new settlements during the latter stages of the Plan Period to compensate for lower delivery in earlier years and maintain supply across the Plan Period as a whole.

2.2.8 The emerging Local Plan also places significant reliance on existing commitments. As the Plan period commenced in 2024/25, delivery data is now available for the first two years, providing a clearer basis for comparing the Council's assumptions with actual housing delivery. This comparison is set out in the table below.

Table 2.4: Comparison between 2026 Regulation 18 and 2026 Regulation 19 - Monitoring

[Please refer to the submission attachments for the referenced figure.]

2.2.9 The table above demonstrates that there is a year-on-year volatility between forecast and actual housing delivery during the opening years of the Plan period. This reinforces the need to allocate additional smaller -sized sites capable of delivering homes early in the Plan period, thereby increasing the resilience of the housing trajectory and supporting the availability of a sufficient supply of deliverable dwellings upon adoption.

2.3 Concerns over Five Year Housing Land Supply on Adoption

2.3.1 Paragraph 3.2.85 of the Addendum calculates the five year housing land supply for the Plan Period, considering both the Sedgefield and Liverpool methods with a 5% buffer. The Addendum favours the Liverpool method given that it focuses on the delivery of new settlements at the later stages of the Plan Period.

2.3.2 For the reasons set out above, and specifically the disparity between forecast and actual delivery during the opening years of the Plan period, our client considers that the Sedgefield method provides the more appropriate basis for assessing five year housing land supply, rather than the Liverpool method. Paragraph 3.2.88 of the Addendum confirms that the anticipated completions undertaken in the years prior to the adoption of the Local Plan are significantly below the standard method figure (614 dwellings compared with 2,289 in the latest 2026 standard method). This is supported by the historic completions for 2024/25 and 2025/26, which indicate that housing delivery has fallen below the standard method requirement during this period (Figure 2 of the Addendum). The 614 dwellings is the difference between the adopted annual housing requirement of 1,675 dwellings against the standard methodology figure of 2,289 dwellings.

2.3.3 Planning Practice Guidance indicates that local planning authorities should seek to address unmet housing need within the first five years of the plan period, where possible. The use of the Sedgefield method would reflect this approach by seeking to address the identified shortfall within the five-year period, rather than distributing it across the remainder of the Plan period (paragraph 022 of the Housing Supply and Delivery Guidance)⁵.

2.3.4 In this context, our client considers that the Plan does not provide sufficient flexibility or contingency to respond to foreseeable delivery risks, given that its five-year housing land supply is forecast to be only 5.03 years in 2028/29 and 5.08 years in 2029/30. Although the identified supply is marginally above five years, the limited margin provides little resilience against delayed permissions, slower build-out rates or slippage affecting strategic sites and infrastructure. Relatively modest changes to the assumptions could therefore result in the identified supply falling below the minimum requirement.

2.3.5 The Council's reliance on new settlements and associated strategic infrastructure, together with the reduced contribution from new allocations during the early years following adoption, raises concerns as to whether the housing strategy will be effective and deliverable, and ultimately potentially unsound. Allocating additional small and medium-sized sites capable of contributing early within the Plan period would strengthen the five-year supply and improve the flexibility and resilience of the housing trajectory. Further details of the Plan's reliance on strategic sites are set out below. Therefore, our client considers that the Site should be allocated to help contribute to the early need. It is in a sustainable location and is ideally suited to accommodate housing.

2.4 Overreliance on Strategic Sites

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

2.4.2 The Addendum adds that new allocations will be phased from 2034/35 onwards on the completion of the Grafham Water Supply Transfer and the delivery of other infrastructure. Our client raises queries as to how Grange Farm and Cambourne North can be delivered earlier than 2034/35 given that both rely on the provision of key pieces of infrastructure (principally transport projects). These have been considered in further detail below.

Grange Farm New Settlement

2.4.3 The Addendum states that the Grange Farm New Settlement will seek to deliver 2,550 dwellings within the Plan Period, with first completions anticipated in 2034/35, contributing an annual delivery of up to 300 dwellings (paragraph 3.2.62). The Addendum acknowledges that one of the key pieces of infrastructure needed prior to the commencement of development is the Cambridge South East Transport (CSET) Phase 2 Scheme. The CSET would provide a new busway between a new A11 travel hub and Cambridge Biomedical Campus.

2.4.4 The CSET is reliant on third party land. The Addendum acknowledges that the timescales for the delivery of the CSET are still being determined and, therefore, a "timely delivery of the CSET extension for early phases will determine whether the full build-out will be able to align with the typical assumptions or not" (paragraph 3.2.67). Given this uncertainty, our client considers that the assumed first completions in 2034/35 may be optimistic, as significant supporting infrastructure must be delivered within the required timeframe. Any delay to CSET or other necessary sustainable transport infrastructure could delay the commencement of development, constrain the initial phases or reduce the anticipated rate of housing delivery.

2.4.5 A comparable infrastructure dependency exists at Bourn Airfield, where delivery is limited to 500 dwellings until either a strategic transport intervention is provided or an updated Transport Assessment demonstrates that further development can be accommodated. Although the circumstances at Grange Farm are not identical, this illustrates how dependencies on strategic transport infrastructure can affect the timing and scale of housing delivery. The uncertainty surrounding the delivery of CSET therefore represents a material risk to the assumed delivery of 2,550 dwellings at Grange Farm during the Plan period.


Cambourne North

2.4.6 Cambourne North is reliant on the delivery of two key pieces of transport infrastructure (the Cambourne to Cambridge public transport corridor (C2C) and East West Rail). Our client acknowledges that C2C has been granted a Transport and Works Act Order. It is anticipated that construction will be take place between January 2027 to December 2030. However, the Addendum notes that final timings are still being discussed and agreed, particularly as third party land is required for the delivery. Therefore, the number of dwellings delivered during the Plan Period could potentially be restricted.

2.4.7 Regarding East West Rail, it is understood that the Highways Authority does not consider that the station needs to open prior to the delivery of housing at Cambourne North. Notwithstanding this, our client considers that the emerging Local Plan is too reliant on the delivery of both pieces of infrastructure. As stated in its Regulation 18 representations, there are no guarantees that a future government would be as committed to the delivery of East West Rail. Therefore, the emerging Local Plan should consider identifying more growth, including at existing smaller settlements that are considered sustainable, such as Cottenham.

2.4.8 In summary, the delivery assumptions for the two new settlements are considered to be optimistic and are subject to material infrastructure and timing risks. Therefore, our client argues that a greater proportion of housing should be allocated through smaller and medium-sized sites, particularly within existing and adjacent existing settlements. The requirement for smaller allocations as part of a "hybrid" approach is supported by the Addendum (paragraph 3.2.71). Given the Plan's reliance on new settlements, the allocation of additional small and medium-sized sites is necessary to diversify the housing supply, provide greater resilience against delays and support delivery during the earlier years of the Plan period.

2.4.9 The Site off Beach Road, Cottenham is capable of making an early contribution to housing supply before the new settlements are expected to deliver at scale. Its allocation would increase the supply of deliverable housing sites, reduce reliance on major infrastructure-dependent developments and strengthen the flexibility and resilience of the housing trajectory during the early years following adoption. The allocation of the Site would therefore assist in ensuring that the Plan is effective and deliverable and maintains a sufficient five-year housing land supply.

2.5 Concerns over the delivery of Sites contributing to the Local Plan Headroom

2.5.1 The 2026 Addendum has calculated that the housing trajectory provides for headroom of 8.2% (paragraph 3.2.72). It adds that the size of the headroom should reflect the risk of delays during the Plan Period, especially regarding new settlements (paragraph 3.2.76).

2.5.2 The headroom figure is reliant on the delivery within new settlements, which are delivered later in the Plan Period once the infrastructure is provided, such as CSET. Therefore, the headroom should not be considered to be evenly distributed through the Plan Period. Therefore, there are concerns that there is a lack of resilience if there is an undersupply in delivery of 'deliverable' sites on the adoption of the Local Plan. The potential for shortfall is already acknowledged in the Addendum. One of the years for which a shortfall is projected is 2031/32, which is one of the first five years from the adoption of the Local Plan.

2.5.3 Whilst the Addendum highlights, that the anticipated shortfalls in these years are compensated by over delivery in all other years, our client considers that the realistic prospect of an initial shortfall in the first five years means that Greater Cambridge should allocate more small sites to ensure consistent delivery, especially in the first five years. The Site off Beach Road, Cottenham is considered appropriately sized and located to help meet this demonstrable need.

2.6 Justification for Allocation at land off Beach Road, Cottenham

2.6.1 The analysis of the 2026 AECOM Addendum confirms the importance of allocating a balanced range of sites, including smaller sites capable of delivering homes during the early years of the Plan period. The allocation of Land off Beach Road, Cottenham would contribute to the five-year housing land supply, diversify the sources of housing delivery and improve the flexibility and resilience of the overall housing trajectory.

2.6.2 The Site's allocation would further reduce reliance on new settlements which are dependent on large pieces of infrastructure being delivered, such as Cambourne North and Grange Farm. The Site is adjacent to an existing settlement, which has a number of services and facilities, including a Primary and Secondary School, and therefore is sustainably located.

2.6.3 If the Site were allocated, it would contribute towards increasing the supply of 'deliverable' sites. This is especially needed given that the number of 'deliverable' sites has decreased from the Housing Trajectory published as part of the Regulation 18 consultation.

2.6.4 The Site should therefore be considered as an additional housing allocation to strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

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

2.6.6 It is considered that the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan. The size of the Site extends to approximately 13.18 hectares and represents just 0.05% of the Green Belt when compared with the overall Green Belt (approximately 26,090 hectares) in Greater Cambridge.6.

2.6.7 In addition, and as set out in the Vision Document, the development of the Site could provide approximately 6.2 hectares of open space, therefore positively responding to direction to minimise effects on the wider Green Belt. The Illustrative Masterplan within the Vision Document shows high quality landscaping along the southern boundary of the Site, providing a visual containment of the Site. Therefore, the Vision Document demonstrates that this very high bar of fundamentally undermining the purposes of the Green Belt within Greater Cambridge is not reached.

2.6.8 As the Site represents just 0.05% of the Green Belt in Greater Cambridge and the scheme included in the Vision Document already provides measures to minimise effects on the wider Green Belt, it is considered that the development of the Site would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across Greater Cambridge as a whole.
b) There is a demonstrable unmet need for the type of development proposed

2.6.9 As stated above, our client considers that there is a demonstrable need for the type of development to ensure that there is a 'deliverable' supply of housing on adoption of the Local Plan, which reduces the reliance on new settlements.

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

2.6.11 The Regulation 18 representations and the Vision Document demonstrate the sustainability of the Site, which should be read in conjunction with these representations. The current Local Plan Policy S/8 defines Cottenham as a Rural Centre, the largest, one of most sustainable villages in the District. Therefore, it should be considered as a future area to support growth in the emerging Local Plan. This can be achieved by upgrading it from a Minor Rural Centre to a Rural Centre, in line with existing Policy.

2.6.12 In summary, the Site is within easy walking distance of a number of services and facilities, including (inter alia) both Primary and Secondary Schools, shops, GP surgeries and restaurants. The Site is also located approximately 150m to the south-east a bus stop. These provide twice hourly services to Cambridge, which takes around 45 minutes. It is crucial that there is steady growth within these settlements to support these services and facilities in the future.

2.6.13 The Site is in accordance with Paragraph 110 of the NPPF and Policy TR3 in the 2026 NPPF as it is a location which limits the need to travel.
d) Where applicable the development proposed meets the 'Golden Rules' requirements set out in paragraphs 156-157 below

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

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

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

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

2.6.18 Our client is committed to ensuring that the proposed development provides necessary improvements to local infrastructure and would be willing to discuss this with a number of stakeholders throughout the Local Plan process, including Greater Cambridge and Cambridgeshire County Council.

2.6.19 It is recognised that the development will generate a need for contributions in respect of (inter alia) healthcare, education, employment and skills and transport, and our client is committed to mitigating its impact having regard to the 'tests' set out in the NPPF and CIL Regulations.

2.6.20 Our client, therefore, considers that through discussions with stakeholders, it can contribute to improving local and/or national infrastructure and is therefore in accordance with part b).
c) The provision of new, or improvements to existing, green spaces, that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces

2.6.21 The Vision Document highlights the importance of providing open space not just to support new residents but the whole community of Cottenham.

2.6.22 The Illustrative Masterplan includes the provision of a green corridor along the northern edge, creating a green corridor with Brenda Gautrey Way. The Illustrative Masterplan also includes a new community orchard, which not only is beneficial to existing and future residents, but which also provides biodiversity enhancements. Children's play areas are also included throughout the development.

2.6.23 In addition, boundary planting has been enhanced and retained where possible to support biodiversity net gain and maintain the Site's containment. In total, the Illustrative Masterplan is providing 6.2 hectares of open space, which equates to 47% of the total site area.

2.6.24 Therefore, our client considers that the Site accords with part c) of the NPPF paragraph 156. 2.6.25 In conclusion, it is considered that the Site falls within the definition of the grey belt, as set out in the NPPF. Therefore, it should be allocated for residential-led development in future iterations of the emerging Local Plan, as the provision of 200 homes can strengthen the robustness of Greater Cambridge's proposed housing trajectory, particularly in the first five years following adoption.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our client considers that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Our client notes that the number of 'deliverable' sites has decreased in the updated 2026 Housing Trajectory, meaning that there are fundamental concerns that Greater Cambridge will not be able to meet its five year housing land supply on adoption.

3.1.3 The Addendum puts the five year supply at marginally above the minimum requirements. That position relies significantly on existing commitments, despite recent delivery falling below earlier forecasts, and provides limited resilience against further delays or reduced build-out rates.

3.1.4 The Plan also relies substantially on new settlements, which in turn are dependent on large pieces of infrastructure being delivered, such as CSET. Delays to that infrastructure could affect the commencement, phasing and rate of housing delivery. The allocation of additional small and medium-sized sites would diversify the supply and provide greater flexibility and resilience, particularly during the early years of the Plan period.

3.1.5 Our client is pleased that the updated evidence base considers that the Site falls within the definition of grey belt.

3.1.6 Land off Beach Road, Cottenham represents a suitable and deliverable additional allocation. It is adjacent to a sustainable settlement with access to a range of services and facilities, including primary and secondary schools. The Site is capable of contributing approximately 200 homes during the first five years following adoption (first completion estimated Q2 2029 with Site completed Q1 2033 (assumed rate of 1 completion per week)), thereby improving the flexibility, resilience and early delivery of the housing trajectory. Its allocation would assist in making the Plan justified and effective.

3.1.7 Our client requests that the Proposed Submission Local Plan be modified to allocate Land off Beach Road, Cottenham for approximately 200 homes, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

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

Footnotes:
1 Appendix B Comberton
2 Greater Cambridge Green Belt Assessment
3 Housing Delivery Study Addendum 2026-06-30
4 Cambridge Housing Delivery Study Addendum October 2025
5 Housing supply and delivery - GOV.UK
6 https://www.gov.uk/government/statistics/local-authority-green-belt-statistics-for-england-2024-to-2025/local-authority-green- belt-england-2024-25-statistical-release

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