1. Paragraph 61 of the NPPF identifies that the minimum number of homes needed within a plan period should be assessed using the Standard Method. An alternative approach should only be used where there are exceptional circumstances to reflect current and future demographic trends and market signals. Based on the Governments’ Standard Methodology, the Council's housing need figure is 36,600 dwellings over the plan period (2020-2041). The Development Strategy Topic Paper (DSTP) outlines that this scale of housing provision would support the creation of 45,800 jobs in Greater Cambridge over the plan period.

2. When assessing Cambridge's future employment and housing needs, it is important to recognise the city's unique regional, national and international standing as a research and innovation employment centre. The Centre for Cities March 2021, ‘Fast Growth Cities – 2021 and beyond’ identifies Cambridge as one of the fastest growing cities in the UK, with more than 60 per cent of its workers coming from outside Cambridge.

3. The significance of the city is further strengthened through its various strategic alliances, including the Greater Cambridge City Deal, the Oxford-Cambridge Arc, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Local Plan (GCLP). In the context of the GCLP, the Councils have completed work assessing the potential economic growth scenarios and the quantity of new houses needed to support this growth in Greater Cambridge over the plan period. The Housing and Employment Relationship Report (November 2020) (HERR) provides two scenarios for housing needs over the plan period (2020-2041), which are in excess of the Government's Standard Method. Scenario 1 forecasts 58,500 new jobs and a housing need of 44,400 dwellings, while the Scenario 2 forecasts 78,700 new jobs and a housing need of 56,500 dwellings.

4. 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. However, the GCLP First Proposals document is aligned with the lower employment and housing figures forecasted by Scenario 1. Our client welcomes the principle of exceeding the Standard Method figures, nevertheless, given the significant growth expected in Greater Cambridge during the plan period, it is considered that the GCLP should take a more positive and proactive approach to support the economic growth of the area. Failure to do so is likely to result in an unnecessary and unsustainable increase in in-commuting, exacerbating unsustainable travel patterns. The Councils should undertake further work to establish a housing requirement within the range stated in the HERR or plan for the higher figure.

Neighbourhood Planning

5. Paragraph 66 of the NPPF outlines that strategic policies should identify the housing requirement for a Neighbourhood Plan Area. However, the First Proposals document states that Neighbourhood Plans housing requirements would be met using the Local Plan windfall housing numbers. R2 Development objects to this approach, which is contrary to Paragraph 66 of the Framework.

6. The GCLP should proactively allocate a proportionate amount of housing growth to sustainable rural settlements, such as Group Villages. Such an approach will be consistent with NPPF with regards to identifying housing requirements, and Paragraph 79 of the NPPF which outlines that planning policies should identify opportunities for villages to grow and thrive, particularly where this will support local services. The adoption of the GCLP should trigger the formal review of an adopted Neighbourhood Plan to ensure that distributed growth to sustainable settlements is allocated at sustainable sites within the Neighbourhood Plan Area.