Greater Cambridge Local Plan: Proposed Submission

An additional paragraph should be added Policy S/JH as follows:

“If a Neighbourhood Plan with sufficient allocations to deliver the housing requirement in full has not passed independent examination and referendum and been ‘made’ by the date two years after the Local Plan is adopted, then the local planning authority will instead make the allocations in either a Local Plan Review or other Development Plan Document. This is to ensure the delivery housing at sustainable settlements such as Group Villages in the rural area of South Cambridgeshire.”

1.1. Policy S/JH: New jobs and homes confirms that the objectively assessed housing need for Greater Cambridgeshire for the period 2024-2045 is a minimum of 48,069 new homes (2,289 new homes per annum). This minimum number of new homes are required to deliver 73,300 additional jobs in Greater Cambridgeshire in the same period. CEMEX welcomes the Plan’s headline commitment to address local housing need in full.

1.2. Notwithstanding the above, CEMEX still has a concern that the approach to planning for and delivering growth in the Local Plan is still to some extent disconnected from the wider regional and national ambition to deliver accelerated growth in the Greater Cambridge area. The evidence base document “Review of economic data, context and representations, Greater Cambridge Local Plan, June 2026” states that MHCLG’s Greater Cambridge Growth Scenarios (November 2025) set out three growth scenarios for the period 2023-2050:
• Low 100,000 new homes and 145,000 new jobs;
• Medium 125,000 new homes and 187,000 new jobs; and
• High 150,000 new homes and 229,000 new jobs.

1.3. These projections provided to MHCLG by Oxford Economics have all been dismissed by the Councils in the preparation of the Local Plan. The concern is that whilst it is not uncommon for there to be a difference between economic growth scenarios modelled by different parties, the low growth scenario stated above is still in excess of double the growth put forward by the emerging Local Plan. The Cambridgeshire & Peterborough Combined Authority’s (CPCA) Local Growth Plan (October 2025) identifies the potential to double or even triple the size of the economy in the period to 2050.

1.4. CEMEX believe the above projections and ambitions highlight a significant missed opportunity by the Councils to deliver more ambitious levels of growth via the emerging Local Plan. It feels as if the ambitions of MHCLG and the CPCA have been dismissed simply because the growth ambitions were published late in 2025, likely to close to the publication of the Regulation 18 Local Plan. This decision could ultimately stifle the economic growth of Greater Cambridge and or result in additional unplanned economic growth coming forward without a defined and robust strategy to deliver the required supporting housing growth. The latter scenario would heap further housing affordability and availability pressures on Greater Cambridgeshire housing market at a time when there are already chronic existing problems relating to these two matters.

1.5. Accordingly, it is even more important that the proposed supply of homes in the Local Plan is robust. CEMEX’s representations to Policy S/DS: Development Strategy will address this matter in full. However, of relevance to Policy S/JH is the approach to delivering new homes in Neighbourhood Plan Areas (NPA). Appendix C of the Local Plan provides the housing requirement for designated NPAs. Appendix C lists 27 designated Neighbourhood Plan Areas and allocates a total of 1,553 dwellings to be delivered across these Areas.

1.6. As stated at paragraph 2.22 of the Local Plan, it is not mandatory for a Neighbourhood Plan to include a housing requirement or identify sites to meet a housing need. Indeed, in the case of Orwell, early indications from the Parish Council (a key element of the Neighbourhood Plan Group) is that their emerging Neighbourhood Plan will not contain a housing requirement of site allocations. Indeed, this is a common approach across the country.

1.7. The Local Plan appears to include the 1,553 dwellings from Neighbourhood Plans in the Plan’s overall Windfall Allowance of circa 6,660 dwellings over the Plan period. This equates to 23% of the already high windfall allowance. CEMEX have concerns that should a Neighbourhood Plan not make allocations, as is relatively commonplace, new sites will not come forward in these NPAs and ultimately the overarching housing targets set out in the Plan will not be met. Alternatively, a Neighbourhood Plan may simply not come forward or be Made, which again would result in housing need being unmet.

1.8. In the neighbouring local authority of Uttlesford District Council (UDC) their new Local Plan (adopted March 2026) takes a positive and proactive approach to housing delivery in this regard. Core Policy 19: Rural Area Housing Requirement Figures states:

“If a Neighbourhood Plan with sufficient allocations to deliver the housing requirement in full has not passed independent examination and referendum and been ‘made’ by the date two years after the Local Plan is adopted, then the local planning authority will instead make the allocations in either a Local Plan Review or other Development Plan Document. This is to ensure the delivery of the Larger Villages housing requirements during the plan period."

1.9. It is strongly contended that Policy S/JH and Appendix C should be amended to include similar policy wording to the above to ensure housing in Rural Areas is delivered and that Windfall Sites come forward at the proposed rate. Without this additional wording Policy S/JH cannot be considered positively prepared, justified or effective in the context of paragraphs 36 a), b) and c) of the National Planning Policy Framework.

The housing need and the ‘total additional homes be identified to meet need’ figures stated in Table 1 which supports Policy S/DS should be preceded by the word ‘minimum’ in order consistent with national planning policy and comply with paragraph 36 a) and 36 d) of the National Planning Policy Framework.

Windfall Sites should be disaggregated from the committed supply stated in the Local Plan and there should be continuity as to the correct Windfall Site figure between the Local Plan and the housing trajectory Housing Land Supply evidence.

Further site allocations should be made in the rural areas of South Cambridgeshire, particularly at Group Villages, to ensure the proposed housing trajectory is truly flexible and deliverable. In its current form the Development Strategy is not considered to be positively prepared or effective as it jeopardises the Plan’s ability to deliver its minimum housing need and support the sustainable growth and vibrancy of rural communities. Thus, it is contrary to NPPF paragraphs 36 a), b) and d).

Policy S/DS Development Strategy directs employment and housing growth to five specific areas or settlement types in Greater Cambridgeshire in an order of preference with top of the list being within the Cambridge urban area and the bottom of the list being “the rural southern cluster and the wider rural area at Rural Centres and Minor Rural Centres”.

Supporting Table 1 in the Local Plan confirms that after taking into account the existing committed supply of 38,378 homes the Local Plan needs to find sites to deliver 9,691 dwellings to deliver the housing need in full. The approach to the distribution of making new allocation in the Local Plan is summarised as follows:
• CAMBRIDGE URBAN AREA: 321 dwellings across eight sites = 2.4%
• EDGE OF CAMBRIDGE: 7,800 dwellings across four sites = 57.1%
• NEW SETTLEMENTS: 5,220 dwellings across three sites = 38.2%
• RURAL SOUTHERN CLUSTER: 103 dwellings across two sites = 0.8%
• REST OF RURAL AREA: 210 dwellings across three sites = 1.5%
• TOTAL: 13, 654 dwellings (providing a buffer of 3,963 dwellings)

The above demonstrates that approx 95% (13,020 dwellings) of the proposed new allocations are located at sites of a strategic scale.

When examining the committed supply, it is evident that there is also a strong reliance on the delivery of strategic sites with approximately 63% (24, 133 dwellings) of supply coming from either New Settlements or strategic sites on the Cambridge fringe. Again, the rural areas of South Cambridgeshire are afforded a limited percentage of the planned growth with 422 dwellings identified over the Plan period (1.2%).

Table 1 of the Local Plan and the Greater Cambridge Housing Trajectory and Housing Land Supply Report (April 2026) identify 313 and 442 dwellings respectively to be delivered at site allocations (existing and proposed) in the rural area of South Cambridgeshire across the Plan period. Of the new allocations only two are identified for delivery at Group Villages, 65 dwellings at Caldecote and 60 dwellings at Duxford. It is unclear as to why these two Group Villages have been identified as being capable of supporting a specific site allocations in the Local Plan; when compared to other 31 Group Villages across the district.

The proposed Development Strategy has been devised by the Councils on the basis of delivering housing growth in the most sustainable locations or the most sustainable options i.e. away from Group Villages in the rural areas due to a perceived over reliance on the private car. However, the Development Strategy is so unbalanced and weighted away from delivering homes at Group Villages in the rural area, it will deliver the stagnation and decline of these settlements. In effect it will make what the Councils perceive to be less sustainable settlements even less sustainable to the detriment of existing communities. Without delivering proportionate and sustainable levels of growth at Group Villages the viability of local services and infrastructure will decline, and the local housing market will stagnate, likely resulting in an ageing population. Local public transport links will become unviable and thus then promote the use of the private car and or isolate residents of these communities – thus delivering the opposite of what the Development Strategy and policies of the Local Plan promote i.e. reducing the reliance on the private car and environmental sustainability.

The Development Strategy is not robust in its approach to providing a flexible housing supply and trajectory which is capable of responding to change in the housing market or delivery rates at strategic sites (the latter being common when considering delays in planning and the need to deliver costly upfront infrastructure).

Whilst the approach to providing a supply buffer is in principle supported by CEMEX, in this case the makeup of the buffer is not sufficient as it is largely formed by strategic sites which make up the supply to meet the initial 9,691 dwelling target. The buffer and wider supply should include non-strategic sites which are deliverable in the short term and without significant investment in new on-site infrastructure.

Without the further allocation of smaller non-strategic sites, at established rural settlements such as Group Villages, it feels inevitable that the Development Strategy and housing trajectory will not deliver the housing requirement established in Policy S/JH.

Windfall Sites
Included in the committed supply figure of 38,378 are Windfall Sites. Paragraph 2.37 of the Plan confirms that the windfall provision is 6,600 dwellings over the Plan period which equates to 314 dwellings per annum. The Greater Cambridge Housing Trajectory and Housing Land Supply Report (April 2026) uses a windfall figure of 425 per annum; thus, clarity is required over which figure is correct. Notwithstanding which figure is correct, CEMEX contend that the total Windfall Site figure should sit separately from the committed supply figure when stated in Local Plan policies and text. Windfall Sites are expected or estimated deliveries not firm commitments arising from a specific site.

Included in 6,660 windfall provision is 1,553 dwellings identified for Neighbourhood Plan Areas. As set out in CEMEX’s representations there is no certainty that housing sites in these areas or indeed Neighbourhood Plans will come forward. Furthermore, there is no review or alternative delivery mechanism in the Local Plan to deliver these dwellings. Accordingly, as a minimum, it is clear that there is significant uncertainty regarding this element of the already committed supply.

Removal of the restrictive limits/thresholds within the policy.

Policy S/SH Settlement Hierarchy sets out a six-tier hierarchy to direct the scale and location of new development in Greater Cambridgeshire. Group Villages, of which there are 33, are described at paragraph 2.124 of the Local Plan as having “services and facilities allowing only some of the basic day-to-day requirements of residents to be met without the need to travel outside the settlement”. On this basis the Policy restricts the scale of development in Group Villages to 8-15 dwellings dependant on specific circumstances applying and the location of the development in the context of Development Framework boundary.

Many of the villages in the Greater Cambridgeshire have a historic core and a tightly knit street pattern. In addition, the Framework boundaries are drawn tight to the existing built-up areas. Accordingly, the opportunity to deliver Windfall Sites in Group Villages in accordance with the restrictions set out in Policy S/SH is very limited. In effect, the Policy will have a very limited positive impact on delivering housing growth Greater Cambridgeshire needs.

Furthermore, the restrictions set out Policy S/SH simply reflect the adopted Local Plan position and have not been updated to reflect the findings of Planning Inspectors at Appeal. In the period 2014-2018 many planning applications in excess of 15 dwellings were approved at Group Village locations across South Cambridgeshire both by the local authority and at Appeal, this includes an up to 49 dwelling scheme Hurdleditch Road, Orwell (PINS Ref: APP/W0530/W/16/3157596 and LPA Ref: S/3190/15/OL).

In allowing the above referenced Appeal the Inspector confirmed the sustainable credentials of the site and village:

‘In terms of shops and services, Orwell contains a village store (including post office), a public house, a hairdresser, a village hall, church hall, some recreation facilities and a mobile library service. Whilst located just outside of the village framework, the proposal would be within reasonable walking distance of facilities within the village. Such facilities would be unlikely to fully cater for the day-to-day needs of residents of the village including those of the proposed development. Nevertheless, whilst being limited I consider that they provide a reasonable level of facilities providing residents with the opportunity for some day to day needs to be met without needing to travel by car.’ (Paragraph 16)
‘….the site is located adjacent to Petersfield Primary School which has capacity to accommodate the primary school needs of the proposed development. There is a secondary school in nearby Bassingbourn which also has sufficient capacity and is accessible from the village via a school bus service operating from the village. Access to early years and sixth form education provision would be more limited, but overall, the site has reasonably good access to local education provision.’
‘In terms of the opportunity to access other facilities by public transport, the proposal includes provision for two new bus stops to be provided on Hurdleditch Road close to the site. This would provide access via bus to Cambridge, though such provision would be constrained by the limited frequency of buses. Other bus services to nearby centres would also be available but their use would also be constrained by the infrequency of services.’ (Paragraph 20)
Further opportunities for travel by rail would be available from the nearby railway station at Shepreth with reasonably regular services on the Cambridge to London line, including stops at Royston, Hitchin and Stevenage….’ (Paragraph 21)

The Orwell Appeal decision, and many other similar decisions, provide a strong and clear indication that the thresholds set out in Policy S/SH are not reflective of a settlement’s actual sustainability and ability to accommodate growth.

As per CEMEX’s representations to Policies S/DS and S/J, Policy S/SH also plays a role in undermining the Local Plan’s ability to meet the overarching housing requirement, maintain a five-year housing land supply over the course of the Plan period and deliver the growth rural settlements need to survive and thrive.

To ensure the Council delivers its minimum local housing need our client’s site at Orwell should be allocated for development along with other deliverable and suitable sites at other Group Village locations.

CEMEX’s other representations outline why there is a need to allocate this site i.e. the trajectory is not robust, not a big enough buffer in the supply and spatial strategy will result in the decline of sustainable village settlements.

Paragraph 3.5.1 sets out that the Councils,
“Want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around.”

To deliver the above ambition only one site allocation is proposed at a Group Village in the rural area, this is a 65-dwelling site at Caldecote. The other Group Village with an allocation is in the “southern rural cluster” area at Duxford (60 dwellings). There are 33 Group Villages in South Cambridgeshire all of which possesses services and infrastructure capable of supporting some of the day-to-day needs of residents.

In short, the Local Plan will not achieve its above stated ambition if further growth does not get allocated in rural areas and associated strategic housing policies are amended to reflect previous decisions from the LPA and PINS at a time when there was a recognised shortfall
of housing in South Cambridgeshire.

The Council’s Call for Site process has resulted in the promotion of hundreds of potential housing sites at Group Village locations, many of which could support housing growth and the formulation of a more balanced, flexible and robust housing trajectory.

CEMEX is promoting Land to the west of Malton Road, Orwell (Site ID 115806 & HELAA Site ID 40324) to deliver a sensitive and proportionate extension to the village. To support the ongoing promotion of the site a package of revised material has been submitted~:

• Location Plan – showing a reduced site area measuring 5.25ha.
• New Masterplan – showing a development of up to 75 dwellings.
• New Access Plan – showing that a comprehensive and robust access strategy can be delivered.
• Landscape and Visual Note.

Delivering sustainable and proportionate levels of housing growth at Orwell is of vital importance in order to support existing local services. A key example is the local primary school. As of June 2026, GOV.UK confirms that Petersfield Primary School has a capacity of 210 pupils but only 125 pupils on the role. The delivery of new homes and thus new pupils would aid the long-term viability of the school. The same can be said for the village’s public transport links, shops and services set out in Table 1 (below). Table 1 provides an up to date review of the village service provision and demonstrates that the village is a sustainable location to accommodate reasonable levels of housing growth.

The 2017 Appeal decision at Hurdleditch Road, Orwell (PINS Ref: APP/W0530/W/16/3157596 and LPA Ref: S/3190/15/OL) confirmed that the village possesses,

“existing local facilities and services providing for some day to day needs of residents and would allow for the opportunity for some journeys to be made by public transport to facilities and services located further afield (Paragraph 23)”

The above confirmation from an independent Inspector indicates that Orwell, like many other Villages in South Cambridge, are not completely care dependant to the extent that they are not capable of supporting proportionate levels of housing growth to meet local needs. The Local Plan is promoting a spatial strategy and settlement hierarchy that will lead to the stagnation of sustainable settlements to the detriment of existing local shops, services and infrastructure.

Table 1 – Orwell Service Provision
[Please refer to the submission attachment for the referenced table.]

The Land west of Malton Road, Orwell has been subject to assessment via the Council’s HELAA process. CEMEX has reviewed this assessment and believe it to be flawed and or unduly negative on a number of technical matters. Table 2 (below) sets out the latest HELAA review of the site, with supplementary commentary from CEMEX given their advanced knowledge of the site.

Table 2 – CEMEX HELAA Commentary
[Please refer to the submission attachment for the referenced table.]

As demonstrated by the contents of Table 2, the Land to the west of Malton Road, Orwell is clearly suitable for development. Any potential constraints can be mitigated by planning condition, planning obligations or by adopting a sensitive design approach. Indeed, the latter approach has been adopted in preparing the submitted Masterplan.

Should the Councils or future Planning Inspector agree with CEMEX that the Local Plan’s proposed Development Strategy is not robust with regards to supporting rural communities and delivering the overarching housing needs of Greater Cambridge it is recommended that the Land west of Malton Road, Orwell is allocated for development along with other suitable sites at Group Village locations.

In addition, should a review mechanism be added to the Plan to address housing need in Neighbourhood Plan Areas (as advised in CEMEX’s representation to Policy S/DS) the Land west of Malton Road, Orwell should also be considered for allocation.

Moving forward, CEMEX are committed to delivering this site with the current intention being to submit an outline planning application for up to 75 dwellings in Autumn 2026. CEMEX will shortly undertake their own public consultation with the local community and conclude their
technical work underpinning the submitted Masterplan.

[Please refer to the submission attachments for the appendices and further technical details.]

To ensure the Council delivers its minimum local housing need our client’s site at Orwell should be allocated for development along with other deliverable and suitable sites at other Group Village locations.

CEMEX’s other representations outline why there is a need to allocate this site i.e. the trajectory is not robust, not a big enough buffer in the supply and spatial strategy will result in the decline of sustainable village settlements.

Paragraph 3.5.1 sets out that the Councils,
“Want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around.”

To deliver the above ambition only one site allocation is proposed at a Group Village in the rural area, this is a 65-dwelling site at Caldecote. The other Group Village with an allocation is in the “southern rural cluster” area at Duxford (60 dwellings). There are 33 Group Villages in South Cambridgeshire all of which possesses services and infrastructure capable of supporting some of the day-to-day needs of residents.

In short, the Local Plan will not achieve its above stated ambition if further growth does not get allocated in rural areas and associated strategic housing policies are amended to reflect previous decisions from the LPA and PINS at a time when there was a recognised shortfall
of housing in South Cambridgeshire.

The Council’s Call for Site process has resulted in the promotion of hundreds of potential housing sites at Group Village locations, many of which could support housing growth and the formulation of a more balanced, flexible and robust housing trajectory.

CEMEX is promoting Land to the west of Malton Road, Orwell (Site ID 115806 & HELAA Site ID 40324) to deliver a sensitive and proportionate extension to the village. To support the ongoing promotion of the site a package of revised material has been submitted~:

• Location Plan – showing a reduced site area measuring 5.25ha.
• New Masterplan – showing a development of up to 75 dwellings.
• New Access Plan – showing that a comprehensive and robust access strategy can be delivered.
• Landscape and Visual Note.

Delivering sustainable and proportionate levels of housing growth at Orwell is of vital importance in order to support existing local services. A key example is the local primary school. As of June 2026, GOV.UK confirms that Petersfield Primary School has a capacity of 210 pupils but only 125 pupils on the role. The delivery of new homes and thus new pupils would aid the long-term viability of the school. The same can be said for the village’s public transport links, shops and services set out in Table 1 (below). Table 1 provides an up to date review of the village service provision and demonstrates that the village is a sustainable location to accommodate reasonable levels of housing growth.

The 2017 Appeal decision at Hurdleditch Road, Orwell (PINS Ref: APP/W0530/W/16/3157596 and LPA Ref: S/3190/15/OL) confirmed that the village possesses,

“existing local facilities and services providing for some day to day needs of residents and would allow for the opportunity for some journeys to be made by public transport to facilities and services located further afield (Paragraph 23)”

The above confirmation from an independent Inspector indicates that Orwell, like many other Villages in South Cambridge, are not completely care dependant to the extent that they are not capable of supporting proportionate levels of housing growth to meet local needs. The Local Plan is promoting a spatial strategy and settlement hierarchy that will lead to the stagnation of sustainable settlements to the detriment of existing local shops, services and infrastructure.

Table 1 – Orwell Service Provision
[Please refer to the submission attachment for the referenced table.]

The Land west of Malton Road, Orwell has been subject to assessment via the Council’s HELAA process. CEMEX has reviewed this assessment and believe it to be flawed and or unduly negative on a number of technical matters. Table 2 (below) sets out the latest HELAA review of the site, with supplementary commentary from CEMEX given their advanced knowledge of the site.

Table 2 – CEMEX HELAA Commentary
[Please refer to the submission attachment for the referenced table.]

As demonstrated by the contents of Table 2, the Land to the west of Malton Road, Orwell is clearly suitable for development. Any potential constraints can be mitigated by planning condition, planning obligations or by adopting a sensitive design approach. Indeed, the latter approach has been adopted in preparing the submitted Masterplan.

Should the Councils or future Planning Inspector agree with CEMEX that the Local Plan’s proposed Development Strategy is not robust with regards to supporting rural communities and delivering the overarching housing needs of Greater Cambridge it is recommended that the Land west of Malton Road, Orwell is allocated for development along with other suitable sites at Group Village locations.

In addition, should a review mechanism be added to the Plan to address housing need in Neighbourhood Plan Areas (as advised in CEMEX’s representation to Policy S/DS) the Land west of Malton Road, Orwell should also be considered for allocation.

Moving forward, CEMEX are committed to delivering this site with the current intention being to submit an outline planning application for up to 75 dwellings in Autumn 2026. CEMEX will shortly undertake their own public consultation with the local community and conclude their
technical work underpinning the submitted Masterplan.

[Please refer to the submission attachments for the appendices and further technical details.]

Orwell Neighbourhood Plan area should have a housing requirement well in excess of 23 dwellings. CEMEX’s evidence indicates that the figure should be 223 dwellings.

In its current form the approach to identifying a housing requirement for Neighbourhood Plans is not considered to be positively prepared or effective as it jeopardises the Local Plan’s ability to deliver its minimum housing need and support the sustainable growth and vibrancy of rural communities. Thus, it is contrary to NPPF paragraphs 36 a), b) and d).

Appendix C of the Local Plan provides a schedule of housing requirements for each of the designated Neighbourhood Plans’ in Greater Cambridgeshire. Paragraphs C.3 - C.6 also provides the methodology as to how the Council have set a requirement.

The methodology is predicated on planning for the residual amount of housing left over following the implementation of the Councils chose Development Strategy i.e. the number of dwellings that need to be delivered following deduction of existing supply and proposed site allocations. As set out in other Representations CEMEX objects to policy S/DS:
Development Strategy on the basis that the identification of site allocations is too heavily focused on new settlements and strategic extensions to Cambridge.

Accordingly, CEMEX has a fundamental and automatic objection to the methodology used to define a housing requirement for Neighbourhood Plans; as the housing requirement at sustainable rural settlements, such as Orwell, has been artificially reduced by the Councils
policy decisions regarding development strategy.

CEMEX have instructed housing need specialists, Marrons, to provide a housing needs assessment for the Parish of Orwell. This Assessment is submitted in support of these Representations.

The Assessment concludes that when following the ‘policy off’ methodology advised in Planning Practice Guidance and associated guidance, Orwell has an outstanding housing need of 98 dwellings to 2031, with an additional need this need rising to the 223 by the end of the proposed Plan period in 2045.

Appendix C of the Local Plan identifies a housing need in Orwell of 23 dwellings for the period 2025-2045. This equates to just 10% of the unconstrained ‘policy off’ housing need for the same period.

Putting aside the CEMEX’s concerns regarding the Plan’s overall Development Strategy, it is apparent that the approach to identifying housing requirements for Neighbourhood Development Areas is flawed and totally inadequate. Delivering just 23 dwellings in Orwell over a 20-year plan period will result in the stagnation of the local housing market, limited housing opportunities for young people and threaten the long-term viability of key services and infrastructure such as Petersfield Primary School and public transport links.

[Please refer to the submission attachments for the appendices and further technical evidence.]

Our assessment work indicates that there is a clear need to allocate additional housing sites in the emerging Local Plan to ensure minimum housing needs are met over the Plan period. The Regulation 19 Local Plan is over reliant on strategic sites which often are slow to deliver or do not deliver at the rates anticipated. Furthermore, as outlined in our appended Report sites included within the trajectory are not supported by sufficient evidence to demonstrate that they are deliverable in the context of the national planning policy and guidance.

In its current form the approach to housing delivery (as set out in the housing trajectory) is not considered to be positively prepared, justified or consistent with national policy as it jeopardises the Plan’s ability to deliver its minimum housing need and a five-year supply upon adoption. Thus, it is contrary to NPPF paragraphs 36 a), b), and d).

The Regulation 19 Local Plan seeks to guide development across Greater Cambridge to 2045. Policy S/JH identifies an objectively assessed need for a minimum of 48,069 new homes over the plan period, equivalent to 2,289 dwellings per annum (dpa). The Plan identifies a total supply of around 52,032 homes, providing approximately 8.2% headroom above the minimum requirement.

The Regulation 19 Local Plan proposes a joint and shared housing trajectory between the two Greater Cambridge authorities, Cambridge City Council and South Cambridgeshire District Council (SCDC). This approach follows in the footsteps of the existing adopted Local Plans for both Councils as whilst the two authorities have separate Local Plans the housing trajectory is combined and shared for monitoring purposes. In respect of South Cambridgeshire, this approach is set by Policy S/12: Phasing, Delivering and Monitoring.

In this context it is important to note the content of a September 2026 Cabinet report and decision by SCDC relating to an Addendum to the Greater Cambridge Housing Trajectory and Housing Land Supply Report 2026. The Addendum Report essential decouples the joint housing trajectory set by Policy S/12 and then assesses five-year housing land supply on the basis of the individual local authority areas. This amounts to the Councils superseding or reviewing Policy S/12 and a fundamental element of their existing spatial strategy without public consultation or independent examination. This decision is a clear deviation from strategies set out in the adopted and emerging Local Plan. It is unclear as to how this Cabinet decision and change in approach will affect the policies of the emerging Local Plan and the associated housing trajectory. CEMEX reserves the right to comment further on this matter at Examination stage should the emerging Local Plan be amended to reflect this recent decision.

CEMEX has instructed a detailed review of the housing trajectory supporting the Regulation 19 Plan, including a five-year housing supply assessment. This Report is appended to this Statement.

The Report concludes that the Councils’ published supply position relies upon assumptions which are, in several respects, optimistic. Reliance is placed upon future base dates, anticipated completions, ambitious lead-in times and build-out rates, and pro-forma evidence from site promoters which does not consistently amount to the clear evidence required by national policy for category B sites.

Having reviewed the sources of supply, the deliverable supply should be reduced by 2,470 dwellings for the period 2025-2030 and by 3,923 dwellings for the period 2026-2031. These reductions reflect the absence of clear evidence that the relevant sites, parcels or phases will deliver housing completions in the timescales and numbers assumed by the councils.

The most robust current assessment is the 2025-2030 position, because it is based upon a known base date and known completions. That assessment identifies a deliverable supply of 9,705 dwellings against a requirement of 12,641 dwellings, equivalent to 3.84 years’ supply and a shortfall of 2,936 dwellings. The 2026-2031 assessment produces a similar result, identifying 9,611 dwellings, equivalent to 3.81 years’ supply and a shortfall of 3,019 dwellings.

Therefore in light of the monitoring arrangements set by adopted Policy S/12 (i.e. a joint and shared trajectory) the Councils cannot currently demonstrate a five-year housing land supply. The scale and persistence of the shortfall indicate that the supply position is materially below that required by national policy and that significant additional deliverable sites are required to address the identified need.

In decision-taking, the absence of a demonstrable five-year housing land supply is a material consideration. The presumption in favour of sustainable development is engaged, subject to the application of the relevant policies within the NPPF. This is particularly relevant where proposals would make a meaningful contribution to meeting evidenced housing need, including on sites capable of delivering homes earlier than the strategic sites relied upon within the emerging trajectory.

In plan-making terms, the emerging Local Plan’s reliance upon later delivery from strategic sites, together with limited headroom above the minimum housing requirement, creates a risk that the plan will not provide a sufficiently flexible or resilient supply. Additional deliverable and developable sites should therefore be considered to increase supply, improve early delivery, and provide a more robust buffer against delay, non-delivery and slower than anticipated build-out.

Given the factors discussed above this is considered insufficient and a buffer of at least 15 to 20% should be considered to allow for the inevitable no delivery or slower delivery from some of the identified sites.

[Please refer to the submission attachments for the appendices and further technical evidence.]

This could be rectified by considering additional sites which would deliver early in the plan period.

The Regulation 19 Local Plan seeks to guide development across Greater Cambridge to 2045. Policy S/JH identifies an objectively assessed need for a minimum of 48,069 new homes over the plan period, equivalent to 2,289 dwellings per annum (dpa). The Plan identifies a total supply of around 52,032 homes, providing approximately 8.2% headroom above the minimum requirement.

The Regulation 19 Local Plan proposes a joint and shared housing trajectory between the two Greater Cambridge authorities, Cambridge City Council and South Cambridgeshire District Council (SCDC). This approach follows in the footsteps of the existing adopted Local Plans for both Councils as whilst the two authorities have separate Local Plans the housing trajectory is combined and shared for monitoring purposes. In respect of South Cambridgeshire, this approach is set by Policy S/12: Phasing, Delivering and Monitoring.

In this context it is important to note the content of a September 2026 Cabinet report and decision by SCDC relating to an Addendum to the Greater Cambridge Housing Trajectory and Housing Land Supply Report 2026. The Addendum Report essential decouples the joint housing trajectory set by Policy S/12 and then assesses five-year housing land supply on the basis of the individual local authority areas. This amounts to the Councils superseding or reviewing Policy S/12 and a fundamental element of their existing spatial strategy without public consultation or independent examination. This decision is a clear deviation from strategies set out in the adopted and emerging Local Plan. It is unclear as to how this Cabinet decision and change in approach will affect the policies of the emerging Local Plan and the associated housing trajectory. CEMEX reserves the right to comment further on this matter at Examination stage should the emerging Local Plan be amended to reflect this recent decision.

CEMEX has instructed a detailed review of the housing trajectory supporting the Regulation 19 Plan, including a five-year housing supply assessment. This Report is appended to this Statement.

The Report concludes that the Councils’ published supply position relies upon assumptions which are, in several respects, optimistic. Reliance is placed upon future base dates, anticipated completions, ambitious lead-in times and build-out rates, and pro-forma evidence from site promoters which does not consistently amount to the clear evidence required by national policy for category B sites.

Having reviewed the sources of supply, the deliverable supply should be reduced by 2,470 dwellings for the period 2025-2030 and by 3,923 dwellings for the period 2026-2031. These reductions reflect the absence of clear evidence that the relevant sites, parcels or phases will deliver housing completions in the timescales and numbers assumed by the councils.

The most robust current assessment is the 2025-2030 position, because it is based upon a known base date and known completions. That assessment identifies a deliverable supply of 9,705 dwellings against a requirement of 12,641 dwellings, equivalent to 3.84 years’ supply and a shortfall of 2,936 dwellings. The 2026-2031 assessment produces a similar result, identifying 9,611 dwellings, equivalent to 3.81 years’ supply and a shortfall of 3,019 dwellings.

Therefore in light of the monitoring arrangements set by adopted Policy S/12 (i.e. a joint and shared trajectory) the Councils cannot currently demonstrate a five-year housing land supply. The scale and persistence of the shortfall indicate that the supply position is materially below that required by national policy and that significant additional deliverable sites are required to address the identified need.

In decision-taking, the absence of a demonstrable five-year housing land supply is a material consideration. The presumption in favour of sustainable development is engaged, subject to the application of the relevant policies within the NPPF. This is particularly relevant where proposals would make a meaningful contribution to meeting evidenced housing need, including on sites capable of delivering homes earlier than the strategic sites relied upon within the emerging trajectory.

In plan-making terms, the emerging Local Plan’s reliance upon later delivery from strategic sites, together with limited headroom above the minimum housing requirement, creates a risk that the plan will not provide a sufficiently flexible or resilient supply. Additional deliverable and developable sites should therefore be considered to increase supply, improve early delivery, and provide a more robust buffer against delay, non-delivery and slower than anticipated build-out.

Given the factors discussed above this is considered insufficient and a buffer of at least 15 to 20% should be considered to allow for the inevitable no delivery or slower delivery from some of the identified sites.

[Please refer to the submission attachments for the appendices and further technical evidence.]

It is considered that the council should take a more realistic approach to build-out rates.

The Regulation 19 Local Plan seeks to guide development across Greater Cambridge to 2045. Policy S/JH identifies an objectively assessed need for a minimum of 48,069 new homes over the plan period, equivalent to 2,289 dwellings per annum (dpa). The Plan identifies a total supply of around 52,032 homes, providing approximately 8.2% headroom above the minimum requirement.

The Regulation 19 Local Plan proposes a joint and shared housing trajectory between the two Greater Cambridge authorities, Cambridge City Council and South Cambridgeshire District Council (SCDC). This approach follows in the footsteps of the existing adopted Local Plans for both Councils as whilst the two authorities have separate Local Plans the housing trajectory is combined and shared for monitoring purposes. In respect of South Cambridgeshire, this approach is set by Policy S/12: Phasing, Delivering and Monitoring.

In this context it is important to note the content of a September 2026 Cabinet report and decision by SCDC relating to an Addendum to the Greater Cambridge Housing Trajectory and Housing Land Supply Report 2026. The Addendum Report essential decouples the joint housing trajectory set by Policy S/12 and then assesses five-year housing land supply on the basis of the individual local authority areas. This amounts to the Councils superseding or reviewing Policy S/12 and a fundamental element of their existing spatial strategy without public consultation or independent examination. This decision is a clear deviation from strategies set out in the adopted and emerging Local Plan. It is unclear as to how this Cabinet decision and change in approach will affect the policies of the emerging Local Plan and the associated housing trajectory. CEMEX reserves the right to comment further on this matter at Examination stage should the emerging Local Plan be amended to reflect this recent decision.

CEMEX has instructed a detailed review of the housing trajectory supporting the Regulation 19 Plan, including a five-year housing supply assessment. This Report is appended to this Statement.

The Report concludes that the Councils’ published supply position relies upon assumptions which are, in several respects, optimistic. Reliance is placed upon future base dates, anticipated completions, ambitious lead-in times and build-out rates, and pro-forma evidence from site promoters which does not consistently amount to the clear evidence required by national policy for category B sites.

Having reviewed the sources of supply, the deliverable supply should be reduced by 2,470 dwellings for the period 2025-2030 and by 3,923 dwellings for the period 2026-2031. These reductions reflect the absence of clear evidence that the relevant sites, parcels or phases will deliver housing completions in the timescales and numbers assumed by the councils.

The most robust current assessment is the 2025-2030 position, because it is based upon a known base date and known completions. That assessment identifies a deliverable supply of 9,705 dwellings against a requirement of 12,641 dwellings, equivalent to 3.84 years’ supply and a shortfall of 2,936 dwellings. The 2026-2031 assessment produces a similar result, identifying 9,611 dwellings, equivalent to 3.81 years’ supply and a shortfall of 3,019 dwellings.

Therefore in light of the monitoring arrangements set by adopted Policy S/12 (i.e. a joint and shared trajectory) the Councils cannot currently demonstrate a five-year housing land supply. The scale and persistence of the shortfall indicate that the supply position is materially below that required by national policy and that significant additional deliverable sites are required to address the identified need.

In decision-taking, the absence of a demonstrable five-year housing land supply is a material consideration. The presumption in favour of sustainable development is engaged, subject to the application of the relevant policies within the NPPF. This is particularly relevant where proposals would make a meaningful contribution to meeting evidenced housing need, including on sites capable of delivering homes earlier than the strategic sites relied upon within the emerging trajectory.

In plan-making terms, the emerging Local Plan’s reliance upon later delivery from strategic sites, together with limited headroom above the minimum housing requirement, creates a risk that the plan will not provide a sufficiently flexible or resilient supply. Additional deliverable and developable sites should therefore be considered to increase supply, improve early delivery, and provide a more robust buffer against delay, non-delivery and slower than anticipated build-out.

Given the factors discussed above this is considered insufficient and a buffer of at least 15 to 20% should be considered to allow for the inevitable no delivery or slower delivery from some of the identified sites.

[Please refer to the submission attachments for the appendices and further technical evidence.]

This clearly demonstrates that a significant improvement in housing delivery is required across the Greater Cambridge area.

Additional deliverable and developable sites should be considered to increase supply, improve early delivery, and provide a more robust buffer against delay, non-delivery and slower than anticipated build-out.

The Regulation 19 Local Plan seeks to guide development across Greater Cambridge to 2045. Policy S/JH identifies an objectively assessed need for a minimum of 48,069 new homes over the plan period, equivalent to 2,289 dwellings per annum (dpa). The Plan identifies a total supply of around 52,032 homes, providing approximately 8.2% headroom above the minimum requirement.

The Regulation 19 Local Plan proposes a joint and shared housing trajectory between the two Greater Cambridge authorities, Cambridge City Council and South Cambridgeshire District Council (SCDC). This approach follows in the footsteps of the existing adopted Local Plans for both Councils as whilst the two authorities have separate Local Plans the housing trajectory is combined and shared for monitoring purposes. In respect of South Cambridgeshire, this approach is set by Policy S/12: Phasing, Delivering and Monitoring.

In this context it is important to note the content of a September 2026 Cabinet report and decision by SCDC relating to an Addendum to the Greater Cambridge Housing Trajectory and Housing Land Supply Report 2026. The Addendum Report essential decouples the joint housing trajectory set by Policy S/12 and then assesses five-year housing land supply on the basis of the individual local authority areas. This amounts to the Councils superseding or reviewing Policy S/12 and a fundamental element of their existing spatial strategy without public consultation or independent examination. This decision is a clear deviation from strategies set out in the adopted and emerging Local Plan. It is unclear as to how this Cabinet decision and change in approach will affect the policies of the emerging Local Plan and the associated housing trajectory. CEMEX reserves the right to comment further on this matter at Examination stage should the emerging Local Plan be amended to reflect this recent decision.

CEMEX has instructed a detailed review of the housing trajectory supporting the Regulation 19 Plan, including a five-year housing supply assessment. This Report is appended to this Statement.

The Report concludes that the Councils’ published supply position relies upon assumptions which are, in several respects, optimistic. Reliance is placed upon future base dates, anticipated completions, ambitious lead-in times and build-out rates, and pro-forma evidence from site promoters which does not consistently amount to the clear evidence required by national policy for category B sites.

Having reviewed the sources of supply, the deliverable supply should be reduced by 2,470 dwellings for the period 2025-2030 and by 3,923 dwellings for the period 2026-2031. These reductions reflect the absence of clear evidence that the relevant sites, parcels or phases will deliver housing completions in the timescales and numbers assumed by the councils.

The most robust current assessment is the 2025-2030 position, because it is based upon a known base date and known completions. That assessment identifies a deliverable supply of 9,705 dwellings against a requirement of 12,641 dwellings, equivalent to 3.84 years’ supply and a shortfall of 2,936 dwellings. The 2026-2031 assessment produces a similar result, identifying 9,611 dwellings, equivalent to 3.81 years’ supply and a shortfall of 3,019 dwellings.

Therefore in light of the monitoring arrangements set by adopted Policy S/12 (i.e. a joint and shared trajectory) the Councils cannot currently demonstrate a five-year housing land supply. The scale and persistence of the shortfall indicate that the supply position is materially below that required by national policy and that significant additional deliverable sites are required to address the identified need.

In decision-taking, the absence of a demonstrable five-year housing land supply is a material consideration. The presumption in favour of sustainable development is engaged, subject to the application of the relevant policies within the NPPF. This is particularly relevant where proposals would make a meaningful contribution to meeting evidenced housing need, including on sites capable of delivering homes earlier than the strategic sites relied upon within the emerging trajectory.

In plan-making terms, the emerging Local Plan’s reliance upon later delivery from strategic sites, together with limited headroom above the minimum housing requirement, creates a risk that the plan will not provide a sufficiently flexible or resilient supply. Additional deliverable and developable sites should therefore be considered to increase supply, improve early delivery, and provide a more robust buffer against delay, non-delivery and slower than anticipated build-out.

Given the factors discussed above this is considered insufficient and a buffer of at least 15 to 20% should be considered to allow for the inevitable no delivery or slower delivery from some of the identified sites.

[Please refer to the submission attachments for the appendices and further technical evidence.]