1 These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2 The Development Strategy Topic Paper (DSTP) outlines the Council’s approach to establishing GCLP housing need figure. The housing need figure based on the Governments’ Standard Methodology is 36,600 dwellings, this figure would support the creation of 45,800 jobs in Greater Cambridge over the plan period. As recognised by paragraph 61 of the National Planning Policy Framework (NPPF) local planning authorities can plan for a housing number in excess of the standard method figures should market trends, underpinned by evidence, suggest otherwise.

3 Greater Cambridge is subject to significant growth initiatives and investment (public and private) some of which have already been implemented, with others coming on stream in the plan period. The aims and objectives of the Greater Cambridge City Deal, the Oxford-Cambridge Arc and the Cambridge and Peterborough Combined Authority in terms of job creation and housing growth provide important context in the preparation of the Greater Cambridge Local Plan (GCLP). Accordingly, the Councils have carried out employment forecasting to establish potential growth scenarios and the number of new houses needed to support new jobs in Greater Cambridge over plan period. In principle, this approach is supported by our client.

4 The Housing and Employment Relationship Report (November 2020) (HERR) suggests two scenarios in excess of the Standard Method as follows:

• Provide for 58,500 new jobs in the area over the plan period 2020-2041. To support this growth option a housing need of 44,400 dwellings is required over the over the plan period.

• Provide for 78,700 new jobs in the area over the plan period 2020-2041. To support this growth option a housing need of 56,500 dwellings is required over the over the plan period.

5 The GCLP First Proposals document seeks to support the delivery of 58,500 new jobs and 44,400 new dwellings over the plan period. Whilst the principle of exceeding the Standard Method housing target is agreed and welcomed by our client, given the significant momentum and political weight behind funding, infrastructure improvements and growth initiatives in Greater Cambridge it is considered that the GCLP should take a more positive approach to supporting the economic growth of the area. Indeed, the economy of Greater Cambridge and the Oxford-Cambridge Arc area is of national importance and the established education and innovation sectors are of international importance.

6 The differing outputs of the two economic growth scenarios is too vast for the Councils to conclude at this early stage of the plan preparation process that the GCLP should plan for the lower figure. Indeed, it is noted that the HERR states that the GCLP should plan for economic growth within the range of the two scenarios. The Councils should plan positively through the GCLP to meet the challenges and opportunities presented by the growth initiatives and funding which is focused on Greater Cambridge. Accordingly, it is strongly recommended that the Councils undertake further work to establish a housing requirement within the range stated in the HERR or plan for the higher figure. There is suitable housing land available at established sustainable settlements to support the economic growth of Greater Cambridgeshire.

Neighbourhood Planning

7 The First Proposals document confirms the Councils intended approach to facilitating sustainable housing growth through Neighbourhood Planning. The proposed approach would see Neighbourhood Plans meeting windfall housing numbers, with the Councils identifying an indicative housing requirement (on an informal basis) for a Neighbourhood Plan Area. Our client objects to this approach as paragraph 66 of the NPPF makes it clear that strategic policies should identify the housing requirement for a Neighbourhood Plan Area.

8 To allow rural settlements to thrive and sustain their service provision the GCLP should set the planning agenda by proactively allocating a proportionate housing requirement to established sustainable settlements such as Group Villages. This approach will allow Neighbourhood Plans to come forward with greater clarity and transparency; and also stimulate community planning which is supported by the NPPF. Without proportionate levels of housing growth sustainable rural settlements will stagnate over the plan period and communities run the risk of seeing important services becoming unviable.

9 The GCLP’s proposed approach to Neighbourhood Planning does not comply with paragraphs 66 and 67 of the NPPF and exposes wider shortcomings in the proposed development strategy put forward in the First Proposals document. The GCLP’s approach to promoting Neighbourhood Planning is in need of significant remedy as the plan preparation process continues.