Hallam Land Management (HLM) consider the First Proposals do not plan for an appropriate quantum of new jobs and homes having regard to the available evidence.

A Review of Employment Needs Evidence has been undertaken and is submitted with these representations. The Plan should be planning for a minimum of 78,700 jobs and 56,900 new homes to 2041 (the higher growth scenario) for the reasons set out within the Review and summarised below.

In terms of the job growth target and employment floorspace requirement, the following comments are made:

1. In projecting past trends, the floorspace requirement will constrain jobs growth to levels below what has been forecast, particularly the level forecast by the Cambridge & Peterborough Independent Economic Review (2018) (CPIER);
2. The floorspace requirements do not take into account reductions in floorspace over the Plan period as older or lower quality employment land and buildings are redeveloped for alternative uses;
3. The implications of the growth in logistics arising from changes in the economy, including growth in online retailing, should be considered in light of the findings of the update to the Retail and Leisure Study; and,
4. The implications of the growth in Data Centres on the demand for employment floorspace over the Plan period should be considered.

In terms of the supply to meet the employment floorspace requirement, it is noted that a substantial proportion of the identified supply is not available until post 2041. It cannot therefore contribute to meeting the requirement and the jobs target. Additional supply is therefore required, in the form of new allocations.

In terms of the new homes target, HLM do not support the use of the ‘central scenario’ in planning for future population and housing growth. This level of housing growth in particular will constrain employment growth, and either limit Greater Cambridgeshire’s ability to achieve the ‘higher growth scenario’, or as a consequence place greater pressure on the local housing market, worsening affordability.

There is support for the higher growth scenario within the Council’s Employment Land Review (November 2020), and CPIER led by Kate Barker.

It is noted the Councils reject this level of growth on the basis they consider it is not the most likely future scenario. However, it is requested the Councils reconsider this matter in light of submissions made to this consultation, and look to plan to meet this higher growth requirement to ensure that economic growth is not out of kilter with the planned level of new homes.

In relation to the supply to meet the housing requirement, the Councils should be realistic as to the level of growth it considers can be delivered by 2041 on sites. Paragraph 73 criteria d) of the Framework requires the Councils to make a realistic assessment of likely rates of delivery, given the lead-in times for large sites.

This paragraph is particularly relevant to proposed allocations at North East Cambridge, Cambridge Airport, North West Cambridge, and Cambridge East where cumulatively 10,650 homes are planned to be delivered by 2041. This is in addition to existing commitments and assumptions related to windfalls in the City.

The rate of growth is ambitious, and the Councils will need to review its evidence on the issue of delivery prior to the submission of its Plan for Examination to ensure its assumptions are sound, and that the quantum of development is deliverable.

Similar comments are also made in relation to the changed assumptions around delivery rates at Northstowe and Waterbeach New Town which have not been evidenced (see representations made to Policy S/NS).

If the rate of delivery cannot be justified, the Councils should consider making further allocations to address any shortfall in meeting the housing requirement.

It is in this context that HLM consider the Plan should include a new settlement at Scotland Farm. This should either be in addition to the selected locations in order to bolster supply to meet the higher jobs and homes requirement, or as an alternative to those locations selected that are not taken forward in the Plan.