The intention of Policy S/JH will be to set out the levels of need in Greater Cambridge that development will meet over the Plan Period 2020 to 2041. The Objectively Assessed Need (OAN) has been calculated at 44,400 new homes, reflecting an OAN of 2,111 homes per year.

The overall housing need should be based upon a minimum (emphasis added) figure, in accordance with NPPF Paragraph 61. This is to ensure consistency with national policy and the Governments objective of significantly boosting the supply of homes (NPPF Paragraph 60).

Background studies undertaken to inform the emerging Local Plan (the Employment Land and Economic Development Evidence Study, November 2020 and Greater Cambridge Housing and Employment Relationships Report, 2020) found that the standard housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041 and would risk increasing the amount of longer distance commuting. The OAN has therefore been calculated above the standard housing figure set by government and instead is based upon the most likely level of future jobs. This approach to determine a higher number of homes than the standard method is supported and in accordance with Paragraph 61 of the NPPF, it is considered that the future jobs forecast provides exceptional circumstances to justify a higher level of homes based upon current and future demographic trends and market signals, taking into consideration that the Greater Cambridge economy is dynamic and does not align with national or regional job forecasts.

This is also acknowledged by Cambridge City Council, whom state “Cambridge is a successful city with a world-class reputation for education, science and innovation, research and knowledge-based industries, and its historic environment. It is a major focus for employment. The high-value Cambridge Cluster is crucial to the UK’s economy and its international competitiveness.” This underlines the importance of the Cambridge economy, and in turn the importance of supporting this economy through the delivery of sufficient housing, both to prevent long-distance commuting but also to address and prevent worsening of the existing affordability situation.

The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) considers the future jobs forecast for Greater Cambridge. The study states that 81% (35,800) of the total jobs forecast in the 2018 adopted Local Plans between 2011 and 2031, were created between 2011-17. This suggests that the economic growth potential in Greater Cambridge has previously been underestimated. As a result, the Study considers two job growth scenarios for the emerging Local Plan:
• Central (medium) growth scenario: considered the most likely outcome taking into account long term patterns of employment. Overall this scenario led to aggregate year on year growth comparable with that between 2001-2017 (and 1991 – 2017). A total of 58,500 jobs.
• Higher growth scenario: a higher outcome placing greater weight on fast growth in the recent past. Overall this scenario led to aggregate absolute year on year growth higher than that seen between 2001-2017 (and 1991-2017), but lower than the ‘fast growth’ period of 2010-2017. A total of 78,700 jobs.

The Study suggested that flexibility is provided in employment land in case the market delivers more jobs than anticipated, and this statement is also reflected within the First Proposals document.
We agree that the Greater Cambridge Local Plan should provide flexibility to facilitate higher job growth, and this should be considered and included within the Draft Local Plan. It is clear from the First Proposals’ evidence base that historically the employment growth across Greater Cambridge has been higher than predicted. This is also notwithstanding the recent introduction of Use Class E, which may see greater movement between the previous Class B Uses and additional employment sites coming forward, thereby increasing the need for housing land.

If the Local Plan does not incorporate adequate flexibility, it runs the risk of restricting jobs growth and failing to meet the economic objective of sustainable development, as set out at NPPF (2021) Paragraph 8(a). Flexibility is also required to ensure sustainable economic growth is positively and proactively encouraged, as required by Paragraph 82 of the NPPF.

In providing the necessary flexibility to facilitate higher job growth, it will be necessary for the Greater Cambridge Local Plan to also provide flexibility in the delivery of additional homes to support any additional jobs and to reduce levels of in and out commuting into Greater Cambridge, and the resulting impacts this would have on climate change and congestion. The First Proposal consultation document is clear that commuting from neighbouring authorities or further afield should be restricted, with climate change comprising one of the ‘big themes’ shaping the document.

Whilst it is acknowledged that the Councils are intending to allocate enough sites to provide approximately a 10% buffer to enable flexibility to deal with unforeseen circumstances (this is assumed in circumstances such that a site no longer comes forward for development, or delivery on a site is delayed), flexibility to support higher jobs growth should also be incorporated in the Local Plan.

This would ensure that the emerging Local Plan does not fall short of meeting criterion c) of Paragraph 82 of the NPPF (2021) by failing to provide sufficient housing to support economic growth.

To provide for appropriate flexibility for unforeseen economic growth, a range of additional contingency site allocations should be included within the housing trajectory. This will ensure the Local Plan is positively prepared, justified and effective in accordance with the NPPF (2021) tests of soundness. Land to the East Side of Cambridge Road Melbourn offers a sustainable location for development and is immediately available for development, therefore able to contribute to the Councils’ short to medium housing delivery rates.