Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58616

Received: 13/12/2021

Respondent: Endurance Estates - Caxton Gibbet Site

Agent: Carter Jonas

Representation Summary:

It is considered that the Sustainability Appraisal has not sought to make the emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils.

Full text:

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Endurance Estates that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable. It appears that the assessment against sustainability objectives is not robust because it does not critically review or challenge the evidence provided by the Councils.

Endurance Estates representations and requested amendment to the assessment of policy options in the Sustainability Appraisal, which are relevant to the promoted development for employment uses at land at Caxton Gibbet are as follows:

• Table 5.4: Policy S/DS: Development Strategy - Assesses the development strategy against sustainability objectives. The economy objective (SA14) relates to employment land supply and business needs matters, and the and employment objective (SA15) relates to the availability of and access to employment opportunities. The score of the economy and employment objectives are ‘mixed minor effects likely’. These scores highlight how unambitious the development strategy is towards supporting the economy of Greater Cambridge, supporting businesses and meeting their needs, and providing job opportunities for residents. As set out in Endurance Estates’ representations to Policy S/DS, the need for additional land for industrial and strategic logistics will not be met through the preferred development strategy, and there is no clear strategy to make Cambourne more sustainable by directing strategic employment development to this location. It is considered that the SA should recommend amendments to Policy S/DS to improve the score for economy and employment related sustainability objectives. As requested in the representations to Policy S/DS and S/CB: Cambourne, a specific strategic employment allocation should be made at land at Caxton Gibbet for Class B2 and Class B8 uses, in order to meet the needs for industrial and strategic logistics floorspace in Greater Cambridge and to provide job opportunities close to Cambourne for existing and future residents.

• Table 5.16: Policy S/CB: Cambourne – Identifies ‘significant positive effects likely’ for the economy objective (SA14) and the employment objective (SA15). The commentary for these matters refers to the transport connections as providing an opportunity to attract a new workforce. The assessment and commentary for economy and employment matters is inadequate and not robust. There is already an existing highly skilled workforce available in Cambourne, the problem is that not enough jobs are provided in this location to enable residents to work locally and so they travel elsewhere for employment purposes. It is not a sustainable outcome for most residents of Cambourne, the largest settlement in South Cambridgeshire, to travel to other centres for work, and it is necessary for emerging GCLP to set out a deliverable strategy to increase significantly the amount of job opportunities available in Cambourne during the plan period. As set out in Endurance Estates’ representations to S/CB: Cambourne, it is requested that a specific strategic employment allocation should be made at land at Caxton Gibbet for Class B2 and Class B8 uses, in order to meet the needs for industrial and strategic logistics floorspace in Greater Cambridge and to provide job opportunities close to Cambourne for existing and future residents. This approach would more accurately reflect the ‘significant positive effects likely’ scores currently given for the economy and employment related sustainability objectives.

• Table 5.50: Policy J/NE: New Employment Development Proposals – Identifies ‘significant positive effects likely’ for the economy objective (SA14) and a ‘negligible effect’ for the employment objective (SA15). The ‘negligible effect’ score for the employment objective again highlights the lack of ambition in emerging GCLP to meet the employment needs of all residents. The ‘significant positive effects likely’ score for the economy objective does not take into account the decision to not meet the business needs for additional Class B2 and B8 floorspace – see findings in the Need for Employment Land Report (prepared by Savills) and the Market Demand Report (prepared by Carter Jonas) referred to in representations to Policy S/CB: Cambourne, Policy S/DS: Development Strategy and Policy J/NE. It is clear that emerging GCLP does not intend to accommodate the needs for high and mid-technology manufacturing and strategic logistics floorspace. The SA does not assess the consequences of industrial and logistics floorspace being provided elsewhere and not in Greater Cambridge, or the associated consequences on the economy, businesses, employees and transport. It is considered that there would be negative sustainability outcomes for all these matters. Policy J/NE should seek to deliver an actual ‘significant positive effects likely’ score for the economy and employment related sustainability objectives by meeting the needs for industrial and strategic logistics floorspace in Greater Cambridge and by providing job opportunities close to Cambourne for existing and future residents. This could be delivered by a specific strategic employment allocation at land at Caxton Gibbet for Class B2 and Class B8 uses, as requested by Endurance Estates.

It is requested that the above comments are taken into account when the SA is updated.