The Plan Period:
Emerging Policy S/JH sets out the levels of need that development will meet with regards to jobs, homes and accommodation for gypsies, travellers and travelling showpeople, within Greater Cambridge over the Plan period. The Plan period as set out within the First Proposals runs between 2020 and 2041.

With regards to the identified Plan period, it is considered that this should be extended to at least 2050 in order to align with the Plan period for the OxCam Arc’s Strategic Framework. This would help facilitate for properly planned strategic growth across the wider region over the next 30 years.

Furthermore, page 31 of the First Proposals states that “consistent with the new National Planning Policy Framework, our vision for Greater Cambridge looks not only to the plan period of 2041, but well beyond to 2050, reflecting that significant development identified in our strategy will continue beyond the plan period from the range of strategic sites identified, including the new settlements”. As the Councils allude to, Paragraph 22 of the NPPF now requires policies to be set within a vision that looks further ahead, this being “at least 30 years”, where larger scale developments such as new settlements or significant extensions form part of the strategy for the area. However, chapter 2 of the First Proposals which sets out the Council’s vision and aims and includes Policy S/JH, is titled ‘Greater Cambridge in 2041’; there needs to be clarity around the period that the Councils’ are establishing a vision and planning for and, having regard for the above comments related to the Plan period for the OxCam Arc and the Councils’ proposed use of large scale developments, it is again recommended that this is extended to at least 2050.

Objectively Assessed Needs:
Policy S/JH identifies that within the Plan period, the Local Plan will facilitate development to meet the objectively assessed needs (“OAN”) for 58,500 jobs and 44,400 homes, reflecting an annual OAN of 2,111 homes per year. It is welcomed that the Councils have sought to plan for growth that extends beyond the figure calculated using the standard method in national planning guidance. As identified within the Government’s ‘Indicative Local Housing Needs (December 2020 Revised Methodology)’ table, using the standard method would result in 1,085 homes per year for South Cambridge and 685 homes for Cambridge City, equating to 1,743 homes per year across both authorities, or 36,603 homes over a 21 year Plan period (such as that included within the First Proposals). If the Plan period were to be extended until 2050, using the OAN figure, this would equate to a total need for 63,330 new homes or, 52,290 homes using the Government’s standard method.

Paragraph 61 of the NPPF identifies that “exceptional circumstances” should justify an alternative approach to using the standard method. The evidence for the use of the alternative approach is included at page 22 of the Councils’ ‘Development Strategy Topic Paper’ which states that the ‘Employment Land and Economic Development Evidence Study’ and ‘Greater Cambridge Housing and Employment Relationships Report’, commissioned in parallel by the Councils, found that the standard method housing figure set by Government “would not support the number of jobs expected to arise between 2020 and 2041” and “it would also be a substantially lower annual levels of jobs provision that has been created over recent years”. Planning for this figure would “risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion” and as such, as is also concluded by the Councils at page 23 of the Development Strategy Topic Paper, it cannot be considered that the standard method housing represents the OAN for homes and jobs within Greater Cambridge.

Growth Options:
In turning to look at the identified OAN set out within Policy S/JH, the OAN for 58,500 jobs over the Plan period is based on the ‘medium’ growth level as set out within the Local Plan ‘First Discussions’ consultation. A full range of previously identified growth options for homes, alongside the associated possible jobs outcomes, is included at page 21 of the Development Strategy Topic Paper. The growth options were informed by the work undertaken as part of the Employment Land and Economic Development Evidence Study and Greater Cambridge Housing and Employment Relationships Report and as such is underpinned by suitable evidence however, it is questionable as to whether the most appropriate growth scenario has been applied. Whilst the Councils are planning for ‘medium’ growth as the most likely level of new jobs, the Employment Land and Economic Development Evidence Study also identified a higher growth forecast, placing greater weight on the fast growth experienced in the recent years. The ‘maximum’ growth level would result in 78,700 jobs over the Plan period and 53,500 homes, equivalent to 2,549 homes per year. The Councils identify at page 25 of the First Proposals that they are “mindful” of the fast growth experienced in recent years, albeit it has not been reflected within Policy S/JH.

When referencing the higher employment scenario, the Development Strategy Topic Paper states at page 24 that “by implication from the wording included in the Employment Land Review regarding the central [medium] scenario, this outcome is considered possible but not the most likely”. Firstly, it is assumed that references to the “central” (otherwise known as the ‘medium’ scenario) is a typo and that this should read “higher” (or “maximum”). Secondly, if this growth option is “possible”, then the Councils should be planning for it. As identified within the NPPF, the planning system should be “genuinely plan-led” (paragraph 15) with plans “prepared positively, in a way that is aspirational” (paragraph 16) and strategic policies making sufficient provision for housing and employment development (paragraph 20). Subsequently, failure to plan for this possible growth could result in the Plan being contrary to national policy.

Furthermore, as is identified at page 11 of the Development Strategy Topic Paper, in 2017 the National Infrastructure Commission identified the OxCam Arc as a national economic priority. In light of this, whilst details regarding the quantum of development to be sought through the OxCam Arc Spatial Framework are yet to be determined, it is anticipated that proposed growth levels will be high in order to support the realisation of this national economic priority. Given that a forum for discussion between Greater Cambridge and the Government for the OxCam Arc is yet to be established (as discussed in response to ‘How much development where – general comment’), it is unclear as to what extent the identification of this economic national priority has fed into considerations regarding the Councils’ own future growth plans as set out within the First Proposals. Similarly, within the evidence base, it is not explicitly clear what assumptions have been made with regards to the implications key infrastructure projects such as the A248 improvement works and East West Rail proposals (as discussed in the Commissioners’ response to Policy S/DS) will have on attracting investment and subsequently growth, to the area.

In respect of the above, the Church Commissioners for England would urge the Councils to review the growth assumption applied in calculating the OAN and the justification for not using the ‘higher’ or ‘maximum’ levels.