The Context for Growth and Innovation

1 Paragraph 16b) of the National Planning Policy Framework (NPPF) states that Local Plans will be found sound if they are ‘positively prepared’. In respect of a Plan’s housing requirement, this means that a Plan must ‘as a minimum’ seek to meet the area’s objectively housing need. Paragraph 61 of the NPPF states that the calculation of an area’s minimum housing need should be informed by a local housing need assessment based on the Government’s standard method for calculating housing need. The same paragraph also goes on to confirms that a local planning authority can pursue an alternative minimum figure which “reflects current and future demographic trends and market signals”.

2 Paragraph 81 of the NPPF seeks that planning policies create conditions businesses can “invest expand and adapt”. Significant weight is placed upon the need to support economic growth, both local business needs and wider opportunities. Particular emphasis and importance is placed upon capitalising on opportunities where “Britain can be a global leader in driving innovation”.

3 In considering the jobs and housing requirement it is of vital importance to place great emphasis on the unique role and characteristics of Cambridge and its surroundings in terms of its international role in innovation and key role in the economy not only for the region, but also the wider UK.

4 The ‘Fast Growth Cities – 2021 and beyond’ (March 2021) evidence base document, prepared by Centres for Cities, identifies Cambridge as part of the ‘The Fast Growth Cities Group’ which encompasses some of ‘the most successful and innovative places in the UK”. The document also goes on to state that “Cambridge is one of the most important research and innovation-led employment hubs in the UK” and that Cambridge has “mature innovation systems in place with different strengths and capacity to benefit the entire UK”.

5 As was the case with the existing Local Plans for South Cambridgeshire and Cambridge City, there is a devolution deal in place between the seven local authorities in Cambridge and Peterborough, with the Cambridgeshire and Peterborough Combined Authority created in 2017. The Council’s ‘Development Strategy Topic Paper’ confirms that the aim is to double economic output within 25 years, with an uplift in GVA from £22bn to over £40bn. The Greater Cambridge City Deal also remains a relevant driver for growth in the area with its ambitions to speed up housing delivering, create 45,000 new jobs and provide £1bn of local and national public sector investment. The City Deal document reminds us that “Greater Cambridge competes on a global stage and is a gateway for high-tech investment into the UK. It is also the innovation capital of the country, with more patents per 100,000 population than the next six cities combined”.

6 Since the previous Local Plans were prepared Cambridge has now become an anchor of the national economic priority area known as the Oxford-Cambridge Arc which encompasses the entirety of the Cambridge City and South Cambridgeshire districts. The National Infrastructure Commission’s 2017 report “Partnering for Prosperity: a new deal for the Cambridge-Milton Keynes-Oxford Arc” confirmed that the Arc is home to some of the most productive and fast-growing cities and “has significant potential for transformative growth”. The Ministerial Foreword to ‘The Oxford-Cambridge Arc: Government ambition and joint declaration between Government and local partners’ (March 2019) cites that the Arc is an economic asset of “international standing” and is a place that provides the best of British business and innovation for the benefit of local communities and the wider country.

7 Central to the Arc realising its full potential and Cambridge fulfilling its role as a key anchor of the Arc is the delivering of new housing and infrastructure to complement and support economic growth. Indeed, significant investment has already been made in improving transport infrastructure with the completion of the A14 improvements between Huntingdon and Cambridge and in planning for the East West Rail route between Bedford and Cambridge. There is significant momentum behind planning for the economic prosperity of Cambridge and the surrounding area.

8 The July 2021, ‘Creating a vision for the Oxford-Cambridge Arc’ consultation document published by the Government states the following regarding housing supply in the Arc,

“We are concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.”

9 The consultation document confirms that a Spatial Framework will be developed to provide national planning policy for the Arc area. However, it is clear that Development Plans and local planning authorities will still have an important responsibility to bring forward Local Plans which deliver enough housing to support the four overarching policy pillars of the Spatial Framework: “the environment, the economy, connectivity and infrastructure and place-making”.

Employment Forecasting and Housing Growth

10 In the preparation of the GCLP there is great responsibility on the Councils to prepare a Plan which supports and complements Cambridge’s and the Arc’s national and international role in innovation and business. In addition, the GCLP can also plan positively to achieve economic growth whilst taking advantage of its excellent public transport links and the future benefits of East West Rail. The GCLP should embrace this opportunity of international importance and plan positively for housing to support significant levels economic growth, with residents in the area standing to benefit increased high quality employment opportunities and the committed investment in major transport infrastructure projects.

11 The Council’s Development Strategy Topic Paper (DSTP) summaries the approach the Councils have adopted to define the proposed GCLP housing requirement, drawing upon evidence base studies produced by GL Hearn. The GCLP evidence base indicates that standard method requirement figure for the GCLP area, without accounting for employment forecasting, is 36,600 dwellings. This housing requirement would support the creation of 45,800 jobs. Given the economic growth and investment in the area, and the provisions of the NPPF the Councils have undertaken further economic forecasting to establish potential jobs growth figures and the level of new housing needed to support this growth. The principle of this approach is supported by our client.

12 The Councils are choosing to support the central jobs forecast scenario in the preparation of the GCLP as set out in the Housing and Employment Relationship Report (November 2020) (HERR). This forecast results in a need to plan for 58,500 new jobs in the area over the plan period 2020-2041 and is based on long term patterns of employment continuing, with the year-on-year growth in jobs comparable to that experienced between 2001-2017 and 1991-2017. To support the central level of employment, the GCLP puts forward a medium housing requirement of 44,400 dwellings over the plan period.

13 The HERR also provides an alternative higher jobs forecast which has not been taken forward by the GCLP. The higher forecast could deliver 78,700 jobs over the plan period, this equates to an additional 20,200 jobs when compared to the medium jobs forecast pursed by the GCLP First Proposals. This forecast places greater weight on the fast growth experienced in the recent past, with the year on year growth in jobs higher than that seen between 2001-17 and 1991-17, but lower than the ‘fast growth’ period of 2010-17. To support 78,700 new jobs the GCLP would need to propose a housing target of 56,500 dwellings, 12,100 more dwellings than currently proposed in the GCLP First Proposals. Given the level of investment and momentum behind growth initiatives and funding in Cambridge we consider more likely that the faster growth in recent past will continue, rather than defaulting back to long term employment patterns continuing. Cambridge and its immediate environs has entered a new era of investment and growth.

14 Paragraph 5.22 of the HERR recommends a preferred range “between a central and higher growth scenario” to plan for employment change in Greater Cambridge. Notwithstanding this recommendation, the higher growth option is dismissed by the Council’s in the DSTP, with this option considered as “possible but not the most likely”. This conclusion is based on the “implication from wording in the Employment Land Review regarding the central scenario”. This wording is assumed to be that set out at paragraph 5.22 of the HERR which states that “all economies experience peaks and troughs, with the position at 2017 considered to be a peak or near peak. As a result the most realistic position by 2041 is one which sees outcomes fall back towards the longer term historic year on year absolute change”.

15 It is noted that ONS figures show that between 2000 and 2019 jobs in Cambridge city increased from 93,000 to 123,000, this equates to an average job increase of 1,000 per year. For the period 2014-2016 the job creation growth is reported at exactly 1,000 jobs per year. In the period 2017-2019 job creation increased by 5,000 which equates to an average of 1,666 jobs per annum. Accordingly, since the year considered above to be the ‘peak or near peak’ job creation in the city has not only increased, but it has also increased at a greater average rate than the proceeding period.

16 Job density (total jobs to population) in 2019 was at 1.41, a significant increase on the 1.33 ratio in 2017. Clearly there is a great need to rapidly and significantly increase housing supply in Greater Cambridge to support the current number of jobs in the city. To demonstrate the strong and unique nature of the Cambridge city economy, by comparison in 2019, job density was at a rate of 0.86 in the Eastern region and 0.87 in Great Britain.

17 In light of the recommendations of the HERR, the unique characteristics of Cambridge and the NPPF’s focus on planning policies supporting economic growth and driving innovation it is contended that the GCLP should be seeking to ensure that it is capable of supporting greater economic growth than currently proposed. The HERR recommends pursing a jobs target of between 58,500-78,700 a range of some 20,200 jobs – equivalent to 12,100 additional homes. This range is vast given the importance of the issue and the need for planning policies to be flexible and respond to changing circumstances (NPPF paragraph 33). The higher jobs growth should be planned for or as a minimum further work is required by the Councils to identify an appropriate point within this range for the GCLP to positively plan for. There is significant political, planning and investment momentum behind the economic growth of Greater Cambridge with this momentum set to continue in the 2020-41 plan period. This momentum should be supported by a GCLP which fully embraces the opportunity to deliver economic growth of national importance to support the innovation and science employment sectors which are of acknowledged international significance.

Neighbourhood Planning

18 Paragraph 66 of the NPPF makes it clear that strategic planning policies should identify the housing requirement for a designated Neighbourhood Plan Area. The First Proposals document confirms that the GCLP intends to include a policy which would see Neighbourhood Plans contributing towards meeting windfall housing numbers, with the Councils identifying an indicative housing requirement on an informal basis as when a Neighbourhood Plan Area is designated (or assumed when an existing Neighbourhood Plan is reviewed).

19 This approach in part aligns paragraph 67 of the NPPF which seeks a local planning authority to provide an indicative housing figure. However, as explained in Footnote 33 of the NPPF this approach is only needed when strategic housing policies are out of date or a Neighbourhood Plan Area comes forward after strategic policies have been adopted.

20 The GCLP should be allocating a proportionate housing requirement to established sustainable settlements, particularly those which have a Neighbourhood Plan or are a designated Neighbourhood Plan Area. It should also make it clear that the adoption of the GCLP will trigger the need to review adopted Neighbourhood Plans to assist in meeting housing need at sustainable settlements. This will allow rural communities to thrive and plan proactively and positively for their futures. As set out in our representations on Policy S/DS: Development Strategy it is vital that GCLP pursues a balanced spatial strategy which provides housing choice and benefits all sustainable communities.

21 The proposed approach to Neighbourhood Planning does not comply with the policies of the NPPF (paragraphs 66 and 67) and shines a light on a significant flaw in the proposed spatial strategy in respect of supporting established rural communities and the rural economy (paragraph 84 of the NPPF).