Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58529

Received: 13/12/2021

Respondent: MacTaggart & Mickel

Agent: Rapleys LLP

Representation Summary:

In view of the foregoing, the higher jobs forecast, and therefore the need for the higher level of homes associated with it (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes), is not just possible but is what the evidence suggests is actually the most likely future scenario. Accordingly, this scenario is likely to represent the objectively assessed need for jobs and housing in Greater Cambridge and should be adopted by the ‘First Proposals’ and subsequent drafts of the emerging plan for this reason.

Full text:

“We propose that the new Local Plan will meet the following objectively assessed needs for development in the period 2020-2041:
• 58,500 jobs
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year, which is rounded for the plan.”

• Despite being significant, the level of growth proposed is insufficient.
• Through their ongoing extensive and detailed research, Cambridge Ahead (likely the foremost authority on the mater of Cambridge’s economy and growth), have concluded/demonstrated as follows with respect to the ‘First Proposals’:
> If planned for well, higher growth rates than those proposed can be accommodated in a way that improves quality of life for existing and new residents in balance with the needs of the environment and the economy (i.e. in a sustainable way).
> The most recent growth data does not support the projections expressed in the ‘First Proposals’. This raises concerns that the Councils will again serially underestimate the opportunities that high growth creates.
> Cambridge Ahead’s view is that the long run rates in the ‘First Proposals’ are adopting an under-estimate and do not provide the best possible objective assessment of the area’s growth. As a result, the ‘First Proposals’ risk repeating the previous errors in the EEFM forecasts and ignoring the warnings flagged by the Cambridge Ahead’s CPIER.
> The three complementary arguments underlying the recommended annualised growth scenarios for the emerging Plan – KS3/1.1%, with the possibility of the slightly higher KS2/1.5% - have clear flaws, as set out in GL Hearn’s analysis. The historical reversion to the regional mean was notably higher than the recommended figure. The reasons put forward for discounting the recent performance of the higher exogenous sectors have not provided supporting evidence and therefore lack a credible evidential basis. In addition, the suggestion that the high growth between 2011-17 was peaking and is likely to regress to a future regional or national mean has not only been unconvincingly argued, but has now been convincingly rebutted by the continued high growth of the region.
> Accordingly, Cambridge Ahead do not feel that the recommended Plan annualised growth rates stand up to the test of providing an objective assessment for the region’s proposed future growth.
• Having regard to Cambridge Ahead’s findings therefore, higher rates of growth not just can be provided for (because they can be delivered sustainably) but should be provided for (in order that the levels of growth that current trends show are most likely to occur over the plan period are catered for).
• The growth in jobs and homes proposed in the ‘First Proposals’ and subsequent drafts of the emerging local plan should therefore be increased to the higher jobs and homes scenario (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes).

“What alternatives did we consider?

1. Planning for the higher jobs forecast and level of homes associated with it. This alternative was rejected as this higher jobs forecast could be possible, but is not the most likely future scenario. As such we do not consider that it represents our objectively assessed need, and would therefore not be a reasonable alternative.”

• In view of the foregoing, the higher jobs forecast, and therefore the need for the higher level of homes associated with it (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes), is not just possible but is what the evidence suggests is actually the most likely future scenario. Accordingly, this scenario is likely to represent the objectively assessed need for jobs and housing in Greater Cambridge and should be adopted by the ‘First Proposals’ and subsequent drafts of the emerging plan for this reason.